United States v. J. S. Stearns Lumber Co.
Headline: Treaty-protected reservation land upheld; Court cancels Wisconsin state land patents and blocks state school-section claims, protecting Chippewa allotments and stripping private purchasers' title to those reservation lots.
Holding: The Court reversed and held that lands reserved by treaty and later allotted to Chippewa Indians were not part of Wisconsin’s school-land grant, allowing the United States to cancel conflicting state-issued patents.
- Allows federal cancellation of state patents that conflict with Indian treaty reservations.
- Protects individual Native allotments from state school-land claims.
- Private buyers may lose title and must seek compensation elsewhere.
Summary
Background
The United States sued to cancel land patents that Wisconsin had issued to private buyers, including a lumber company, for sections inside the LaPointe (Bad River) Reservation. The Lake Superior Chippewas had ceded lands in an 1842 treaty but the Nation later set apart the LaPointe Reservation by treaty in 1854. The sections later identified as “sixteen” were surveyed in 1864 and 1873, Wisconsin issued patents in 1881–1887 under its school-land claim, and allotment patents were issued to individual Indians in 1907. Timber was cut from the disputed land from 1909–1912 and sale proceeds were deposited for the rightful parties.
Reasoning
The Court asked whether the earlier treaty reservation and later presidential allotments defeated Wisconsin’s school-section claim. Relying on the Court’s reasoning in a companion decision, the majority concluded the treaty’s reservation and the later allotments were a lawful federal disposition of the lands made before the identifying surveys. Because the reservation and the allotments advanced the treaty purpose to provide homes for the Indians, those lands could not be claimed under the State’s school-land grant. The Court therefore reversed the district court’s dismissal and allowed the United States to proceed to cancel the conflicting state patents.
Real world impact
The ruling protects individual Indian allotments and reservation land from state school-land claims and can strip title from private buyers who received state patents. The State may not keep those sections under the school grant and must pursue any compensation under applicable law. The case was remanded for further proceedings consistent with this opinion.
Dissents or concurrances
One Justice, McReynolds, took no part in the consideration or disposition of this case.
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