Chase v. United States
Headline: Omaha tribe member’s claim to an 80-acre allotment blocked as the Court upholds a 1912 federal law allowing sale of unallotted reservation land, removing the allotment right
Holding: The Court held that the 1912 Act effectively superseded earlier allotment laws, so the Omaha tribe member born after 1893 had no right to an allotment and the lower courts’ dismissal was affirmed.
- Denies allotment claims by Omaha members born after 1893.
- Authorizes sale of unallotted reservation lands under the 1912 act.
- Gives the Secretary authority to reserve or sell lands instead of making allotments.
Summary
Background
Hiram Chase Jr., an Omaha Tribe member, sued claiming a right to select eighty acres from the Omaha Reservation after the Secretary of the Interior denied his selection. Treaties in 1854 and 1865 and an 1882 law set up allotments of reservation land in severalty, held in federal trust for 25 years, with remainder land to be patented to the tribe. An 1893 law expanded some allotments to women and children born after earlier distributions. Chase was born after 1893 and claimed entitlement under those acts.
Reasoning
The core question was whether the 1912 Act, which authorized surveying, appraising, and selling all unallotted Omaha Reservation lands, removed the right to later allotments. The Court agreed with the lower courts that the 1912 law covered the whole subject and could not be reconciled with continuing allotments under the 1882 act. The opinion relied on earlier decisions about Congress’s power over tribal lands and explained that both selling the lands and continuing the allotment program could not stand together. Because the Secretary denied Chase’s claim under the 1912 law, Chase lost.
Real world impact
The ruling means individuals like Chase, born after the earlier allotment rounds, cannot force an allotment when Congress has enacted a comprehensive plan to sell unallotted reservation lands. The Secretary’s authority to reserve or sell those lands under the 1912 statute was upheld. This decision affirms the lower courts’ dismissal and leaves the reservation’s unallotted lands subject to sale under the 1912 law.
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