United States v. Anderson

Background

The federal government brought criminal charges against a private buyer, O. T. Anderson, who purchased fifteen head of cattle from two members of the Klamath Indian Reservation. The cattle had been bought by the Government with money appropriated under an agreement that the Klamath, Modoc, and Yahooskin Indians made with the United States and were delivered to the reservation in 1909 for distribution to tribal members. The indictment said the sale violated an 1884 law that forbids selling cattle bought by the United States and in the possession or control of Indians to anyone not in the tribe without the agent’s written consent.

Reasoning

The Court considered whether the 1884 law covered cattle that the Government bought and then issued to individual Indians. The lower court had combined unrelated appropriation language with the sale ban and concluded the issued cattle belonged to the Indians so the statute did not apply. The Supreme Court reversed that view. It found the statute’s plain text covers "cattle purchased by the United States" that are "in possession or control" of Indians, and that sales to non-tribe members without the Indian agent’s written consent are prohibited. The Court explained the law’s purpose was to protect the Indians who were to benefit from the purchases, not merely to preserve Government title.

Real world impact

The ruling means buyers who purchase reservation cattle bought for tribes can face criminal charges if the sale lacks the written consent of the tribe’s agent. It affirms that cattle bought with Government funds remain subject to the federal ban even after delivery and individual branding to tribal members. Because the decision reversed a dismissal, it settled the legal scope of the statute rather than resolving every factual issue about individual guilt.