Campbell v. Wadsworth
Headline: Court reversed and held that final tribal rolls control inheritance, blocking Creek‑enrolled widow and daughters from claiming a Seminole allotment and favoring the Seminole roll heir listed on the final roll.
Holding: The Court ruled that Congress’s approved final tribal rolls govern who may inherit tribal allotments, so the Creek‑enrolled widow and daughters cannot inherit the Seminole allotment, and the Seminole roll heir prevails.
- Final tribal rolls determine who can inherit tribal allotments.
- Courts cannot rewrite approved rolls except for fraud or mistake.
- People enrolled in one tribe cannot claim another tribe’s allotments.
Summary
Background
Louis Cox died intestate in 1901. He is listed on the final Seminole roll. His widow, Annie Wadsworth, and two daughters, Maggie Beamore and Nancy Alexander, appear on the Creek roll; the Seminole roll notes "Wife and family Creeks." Cox had not been allotted land before his death, but the disputed tract was later allotted as his Seminole distributive share. Lucy Wildcat, a relative on the Seminole roll, claimed the land; the widow and daughters sought to quiet title in state court and won in Oklahoma’s highest court.
Reasoning
The Court asked whether the statutory words "Seminole citizens" could be read more broadly to include the widow and daughters who were enrolled as Creeks. It held that the statute’s first paragraph defines who are "Seminole citizens," and the same definition must apply in the inheritance provision. The Commission to the Five Civilized Tribes compiled the final rolls, and those approved by the Secretary of the Interior are conclusive. The daughters were placed on the Creek roll according to tribal custom that children follow their mother’s tribe, so they cannot be treated as enrolled Seminole citizens. The Court refused to rewrite the statutory rolls and reversed the Oklahoma decision.
Real world impact
The decision enforces the finality of approved tribal rolls when deciding who may inherit tribal allotments. Courts may not expand enrollment lists by interpretation; only fraud or mistake can unsettle a final roll. The ruling affects heirs to Indian allotments and sends the case back for further proceedings consistent with this opinion.
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