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United States v. Navajo Nation

Docket No.: 07-1410
Certiorari Granted: Oct 1 2008
Argued: February 23, 2009
Decided: April 6, 2009

PartyNames: United States v. Navajo Nation
Petitioner: Navajo Nation
Respondent: United States

Court Below: United States Court of Appeals for the Federal Circuit

Navajo Nation
v.
United States
Background:

The Indian Mineral Leasing Act of 1938 (IMLA), 25 U.S.C. 396a et seq., and its implementing regulations authorize Indian Tribes, with the approval of the Secretary of the Interior, to lease tribal lands for mining purposes. In a previous decision in this case, United States v. Navajo Nation, 537 U.S. 488 (2003) (Navajo), this Court held that the Secretary's actions in connection with Indian mineral lease amendments containing increased royalty rates negotiated by the Navajo Nation did not breach a fiduciary duty found in IMLA or other relevant statutes or regulations. The court of appeals held on remand that the Secretary's conduct breached duties linked to sources of law that had been briefed to this Court but not expressly discussed in Navajo.

Question Presented:

1. Whether the court of appeals' holding that the United States breached fiduciary duties in connection with the Navajo coal lease amendments is foreclosed by Navajo. 2. If Navajo did not foreclose the question, whether the court of appeals properly held that the United States is liable as a matter of law to the Navajo Nation for up to ยง600 million for the Secretary's actions in connection with his approval of amendments to an Indian mineral lease based on several statutes that do not address royalty rates in tribal leases and common-law principles not embodied in a governing statute or regulation.

Question:

Does the decision by the Supreme Court in Navajo Nation I, foreclose this most recent decision by the U.S. Court of Appeals for the Federal Circuit? If the decision was not foreclosed, did the U.S. Court of Appeals for the Federal Circuit properly hold that the United States was liable based on its interpretation of statutes that do not address royalty rates in tribal leases?

Holding: reversed and remanded
Vote: 9-0
Opinion By: Justice Antonin Scalia
Read UNITED STATES V. NAVAJO NATION opinion (PDF)
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