Northern Pacific Railway Co. v. United States

Background

The United States sued to annul patents issued in 1895, 1896, 1901, and 1904 to the Northern Pacific Railroad and its successor for certain lands. The Government argued those lands were part of the Yakima Indian Reservation under the 1855 treaty, while the railroad and its buyers relied on an earlier survey (the Schwartz survey) that placed the lands outside the reservation. A later Barnard survey found the larger reservation the Government claimed, a difference of 293,837 acres. Congress also acted in 1904 regarding the Barnard findings and protection for some settlers.

Reasoning

The central question was which survey correctly located the treaty boundary, especially the western line traced to the main ridge of the Cascade Mountains and the area near Mount Adams. The Court examined the treaty’s natural landmarks, contemporary maps and testimony, blazed trees and other boundary marks, the Berry & Lodge field work, and the Indians’ consistent understanding of their western boundary. Balancing the Land Department’s earlier approval of the Schwartz survey against later evidence and congressional action, the Court found the Barnard survey correctly identified the reservation and applied rules giving weight to how the unlettered Indians would have understood the treaty.

Real world impact

The Court affirmed the lower courts’ decree canceling the railroad patents and treating the disputed acreage as part of the Yakima Reservation. The opinion notes that the 1904 statute protects certain prior settlers’ rights, but that those protections did not apply to the appellants in this case. The decision therefore restores large tracts to reservation status and denies the railroad’s patent claims.