Starr v. Long Jim

Background

A buyer sued to quiet title after receiving a 1900 warranty deed from Long Jim and his wife, who were full-blood Native Americans living on part of the Columbia Reservation. The land arose from the 1883 Moses Agreement, ratified by Congress in 1884, which promised allotments to individual Indians. An executive order and later General Land Office decisions recognized an allotment to Long Jim in 1894, but no patent was issued by the United States before the 1900 deed. Congress later authorized and the Secretary issued a patent in 1905 and enacted a 1906 law that kept allotted lands in trust and limited sales during that trust period.

Reasoning

The central question was whether the 1900 deed conveyed fee title to the buyer. The Court held that the Moses Agreement, the 1884 ratifying act, and later executive and departmental decisions show the United States retained title in trust for the Indians, and that Congress’s later patenting actions confirmed there had been no prior fee. Because federal law and public policy kept title with the United States to protect the Indians, a deed made before the patent could not transfer fee ownership, and the warranty in the deed could not estop the Indian grantor from denying title.

Real world impact

The ruling leaves the buyer without fee title from the 1900 deed and affirms government control over Indian allotments until Congress or statutes grant fee patents. It makes clear purchasers cannot rely on private conveyances before patenting and enforces statutory protections intended to prevent premature alienation of Indian land.