United States v. Hemmer

Background

A Sioux Indian named Henry H. Taylor entered a homestead in 1878 and completed the steps required by law to secure title. He received various patents and later faced lawsuits, private conveyances, and county tax assessments and sales that claimed interests in the land. The United States sued to remove those competing claims and to cancel instruments and judgments that it said violated statutory limits on alienating or encumbering the land.

Reasoning

The central question was which congressional law controlled Taylor’s rights: the 1875 law that kept title inalienable for five years, or the broader 1884 law that created a twenty-five year trust for some Indians. The Court examined the text and purposes of both statutes and concluded the 1884 law was prospective and meant to help Indians who had not already acquired rights. Because Taylor had substantially completed the earlier law’s requirements before 1884, the Court held the 1875 law governed his case. The Court rejected the idea that the newer statute implicitly repealed the earlier, more limited statute.

Real world impact

The Supreme Court affirmed the lower-court decree for the United States, leaving in place the protection provided by the 1875 statute and removing competing claims and liens on Taylor’s land. County tax assessments and private conveyances that conflicted with the earlier statutory restriction could not stand. This decision resolves the dispute over which law applied to Taylor and preserves the title protections he acquired under the 1875 act.