Alaska Pacific Fisheries v. United States

Background

The case was brought by the federal government against a California fishing company that in 1916 built a large fish trap near the Annette Islands in southeastern Alaska. About 800 Metlakahtla Indians had settled those islands in 1887, and Congress in 1891 set the Annette Islands aside as a reservation for them. The trap was built without the Indians’ or the Secretary of the Interior’s consent, sat about 600 feet from the high tide line, was designed to catch roughly 600,000 salmon in a season, and would substantially reduce fish available to the island community. A lower court ordered the trap removed, and that decree was appealed.

Reasoning

The Court addressed whether the 1891 reservation covered only the dry land or also the adjacent waters and submerged lands. It concluded that Congress intended the phrase “body of lands known as Annette Islands” to include surrounding waters because the Indians depended on nearby fisheries to feed and support their settlement. The Court relied on the islands’ geography, the Indians’ way of life, the federal government’s power to set aside public property for Indian communities, long-standing administrative practice, and a 1915 Interior Department regulation recognizing the Indians’ control over salmon-trap permits.

Real world impact

Because the Court affirmed the removal order, the decision immediately protects the Metlakahtla community’s access to local fish and prevents similar private traps from operating in those reserved waters without permission. It requires companies to get consent or proper authorization before exploiting fisheries adjacent to the islands and enforces congressional intent to make the reservation self-sustaining for the Indian community.