United States v. Ferguson
Headline: Tribal citizenship rolls decide blood status; Court upheld that the approved roll showing an heir as half-blood lets him legally sell allotted Indian land, blocking oral testimony that said otherwise.
Holding: The Court held that Congress required the approved tribal citizenship rolls to determine an heir’s Indian blood quantum, so the heir listed as half-blood could lawfully convey allotted land and the decree was affirmed.
- Approved tribal rolls control blood-quantum questions for allotment transfers.
- Oral family testimony cannot override the approved roll entry.
- Heirs listed as half-blood on rolls may freely convey allotted lands.
Summary
Background
A man named Kochokney received allotted land as a Creek tribe member and later died. His son, Yekcha, who was enrolled on an approved roll as a Seminole and listed as a half-blood, inherited the land and later made sales. The original owner’s heirs sued to cancel those sales, arguing that if Yekcha was a full-blood he could not lawfully convey the land under federal restrictions.
Reasoning
The Court addressed whether the amount of Indian blood that determines restrictions must be found from the approved tribal citizenship rolls or could be shown by other evidence. The Court relied on statutes that made the commission’s rolls final and directed that blood quantum be determined by those approved rolls. It rejected oral testimony about the mother’s identity and blood status and gave controlling effect to the approved roll entry showing Yekcha as a half-blood. Because the roll showed him as mixed-blood, the Court upheld the lower-court ruling that he was free to make the conveyances.
Real world impact
The decision confirms that, for questions about who is a full-blood or mixed-blood under the allotment laws, courts will generally treat the approved rolls as the decisive record. That means people and buyers can rely on the printed approved rolls when checking whether restrictions apply. The ruling affirmed the lower-court decree allowing the land transfers to stand.
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