Ex Parte Joins
Headline: Challenge to Citizenship Court halted as the Court denies blocking annulment of tribal membership decrees and allows certification to the Dawes Commission, affecting people whose memberships were revoked.
Holding: The Court denied the petition seeking to prohibit the Citizenship Court's annulment and certification of prior membership decrees because the Citizenship Court had completed its judgment and there was nothing left to enjoin.
- Allows Citizenship Court annulments to be certified to the Dawes Commission.
- Leaves individual property and constitutional claims undecided by this Court.
- Prevents prohibition relief once the lower court’s action is finished.
Summary
Background
An individual who had been declared a member of the Chickasaw Nation after winning a United States court judgment sought to stop a special Choctaw and Chickasaw Citizenship Court from undoing that earlier judgment. Congress and the Nations had agreed in 1902 to create the Citizenship Court to review certain citizenship decisions and to certify results to the Dawes Commission. After the new court accepted a case under §31 of the act, it entered a decree annulling many prior membership judgments. The person had invested in tribal land improvements and said the annulment would take away property rights.
Reasoning
The central question was whether this Court should issue an extraordinary order to stop the Citizenship Court from giving effect to its annulling decree or from sending a certified copy to the Dawes Commission. The Justices declined to decide the constitutional or property issues raised because the Citizenship Court had already finished the specific actions it was authorized to take — rendering its judgment and certifying it. Because there was nothing left for this Court to prohibit, the petition for a writ was denied without deciding the merits of the underlying objections.
Real world impact
The decision leaves the Citizenship Court’s annulment and certification in place for now and means individuals cannot obtain a prohibition order once the special court’s authorized work is complete. The Supreme Court did not rule on whether the annulments were lawful or whether property rights were taken, so those substantive claims remain unresolved and could be addressed by other legal processes.
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