United States v. Celestine

Background

A Native American man was indicted for murdering a Native American woman on land within the Tulalip Reservation. Both the defendant and the victim held land patents from the United States. At trial the defendant raised a special plea arguing the United States lacked jurisdiction because of those patents, and the lower court sustained that plea, blocking federal prosecution.

Reasoning

The Court reviewed whether Congress’ laws and treaties left the United States able to punish crimes by one Indian against another on a reservation even when individuals hold patents or have become U.S. citizens. The Court explained that reservations remain part of reservation lands until Congress clearly excludes them. The treaties and the patents here were issued under treaty authority and carried conditions that did not plainly remove federal control. The Court also said that granting citizenship does not automatically show that Congress intended to give up federal jurisdiction. Interpreting the statutes in the Indians’ favor, the Court found it was not clear that Congress intended to renounce federal authority, so the trial court was wrong to bar federal prosecution.

Real world impact

The decision means federal courts can generally try crimes committed by one Native American against another on an Indian reservation even when the individuals hold patents or citizenship. It preserves federal responsibility for serious crimes on reservations unless Congress clearly says otherwise. This ruling opens the way for federal prosecutions that the lower court had prevented.