Onondaga Nation v. Thacher

Background

This case involves a dispute brought in New York state courts about certain wampum belts and whether the University of the State of New York was selected as the official keeper of those items by the Council of the Onondagas. The record in the state courts included findings that the University never purchased the belts and was never actually chosen or raised to the position of wampum keeper. The Supreme Court noted that jurisdiction to review the state judgment is governed by section 709 of the Revised Statutes.

Reasoning

The core question was whether a federal issue had been properly presented in the New York proceedings so the Supreme Court could review the case. The Court found no point in the state record where the validity of a U.S. treaty, federal statute, or federal authority was questioned, nor any clear claim based on rights under the U.S. Constitution or laws. Although counsel argued the state court’s language implied the Onondaga Council lacked power, the Supreme Court concluded no federal question was actually raised or decided below. Relying on that absence, and on precedent cited in the opinion, the Court held it had no authority to review the state judgment.

Real world impact

The decision leaves the New York courts’ findings in place and prevents the Supreme Court from deciding the dispute because no federal claim was presented earlier. Parties seeking federal review must specifically raise federal rights or questions in the state courts; without that, the Supreme Court will dismiss attempts to review state judgments.