Leech Lake Band of Chippewa Indians v. Cass County

108 F.3d 820, 1997 U.S. App. LEXIS 3879, 1997 WL 94023
CourtCourt of Appeals for the Eighth Circuit
DecidedMarch 6, 1997
Docket95-4263
StatusPublished
Cited by2 cases

This text of 108 F.3d 820 (Leech Lake Band of Chippewa Indians v. Cass County) is published on Counsel Stack Legal Research, covering Court of Appeals for the Eighth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Leech Lake Band of Chippewa Indians v. Cass County, 108 F.3d 820, 1997 U.S. App. LEXIS 3879, 1997 WL 94023 (8th Cir. 1997).

Opinions

MURPHY, Circuit Judge.

This ease involves the tax status of land within an Indian reservation which was once alienated from Indian ownership and subsequently reacquired by the tribe in fee simple. In 1993 Cass County, Minnesota levied an ad valorem tax on such fee land owned by the Leech Lake Band of Chippewa Indians. The Band paid the taxes under protest and sought a declaratory judgment that the land is immune from state taxation, an injunction ending the taxation, and an order refunding the taxes' already paid. Based on its interpretation of County of Yakima v. Confederated Tribes and Bands of the Yakima Indian Nation, 502 U.S. 251, 112 S.Ct. 683, 116 L.Ed.2d 687 (1992), the district court granted summary judgment for Cass County. The Band appeals. We affirm in part and reverse in part.

I.

The Leech Lake Band of Chippewa Indians is a federally recognized Indian tribe, whose reservation is located in northern Minnesota. The reservation was created by a series of treaties with the United States government, beginning in 1855 and ending with an executive order in 1874. See, e.g., Treaty with the Chippewas, Feb. 22, 1855, 10 Stat. 1165 (1855); Leech Lake Band of Chippewa Indians v. Herbst, 334 F.Supp. 1001, 1002 (D.Minn.1971). Although the pattern of [822]*822land ownership within the reservation has varied over the years, the reservation has never been disestablished or diminished. See Herbst, 334 F.Supp. at 1002 (D.Minn. 1971) (involving hunting and fishing rights); State v. Forge, 262 N.W.2d 341, 343-44 (Minn.1977) (same).

The Band’s original reservation was impacted by changes in federal Indian policy. During the latter part of the nineteenth century, the United States adopted an allotment policy in order to break up reservations previously established by treaty. This policy granted allotments of land to individual tribal members and sold the often sizable remainder of reservation land to non-Indians. See Felix S. Cohen, Handbook of Federal Indian Law 127-38 (1982). The purpose of the policy was to open land to non-Indians and to assimilate the Indian people into the broader American society. Id. at 128. The overall effect was drastically to reduce the amount of land under Indian control. Id. at 138.

The legislative centerpiece of the allotment policy was the General Allotment Act (GAA), ch. 119, 24 Stat. 338 (1887), (codified as amended in scattered sections of 25 U.S.C.) (sometimes referred to as the Dawes Act). Under the GAA, parcels of land to be granted to individual Indians were initially held in trust by the United States. Section 5 of the GAA provided that after a twenty-five year trust period, the United States would convey the land in fee simple to the individual allot-tee.1 During the trust period the allottees were not permitted to convey the land. Section 6 of the GAA provided that the allottees would be subject to state civil and criminal law.

In 1906 Congress amended the GAA by the Burke Act, ch. 2348, 34 Stat. 182 (1906). The Burke Act amended § 6 of the GAA to make clear that allottees would be subject to state law only after the expiration of the trust period and issuance of a patent in fee simple.2 Yakima, 502 U.S. at 264, 112 S.Ct. at 691. The Burke Act contained a proviso which enabled the Secretary of the Interior to issue a fee simple patent before the expiration of the twenty-five year trust period to “competent and capable” allottees. Burke Act, ch. 2348, 34 Stat. 182 (1906). The proviso stated that land allotted under the GAA would be free from restrictions on “sale, incumbrance, or taxation” when a patent was issued in fee. Id.; see Yakima, 502 U.S. at 264 n. 4, 112 S.Ct. at 691 n. 4.

For the Leech Lake Band and other Minnesota Chippewa tribes, the allotment policy was carried out through the Nelson Act of 1889, ch. 24, 25 Stat. 642 (1889), which partially incorporated the GAA. The Nelson Act created a commission to negotiate with the Band for the “cession and relinquishment” of its reservation land. Id. The Leech Lake Band agreed in 1889 to have land disbursed under the Nelson Act and the agreement went into effect in 1890.

The details of the negotiations with the Leech Lake Band are unclear, but there is some evidence that representatives of the United States told other Minnesota Chippewa tribes that the land allotted to the individual tribal members would not be taxed. During the negotiations a member of the [823]*823White Earth Band of Chippewa Indians asked the United States’ lead negotiator, Harry M. Rice, this question: “I should like to ask whether, when the Dawes bill3 refers to the civil and criminal laws, those provisions apply so as to make our people here subject to the taxation of the white man?” Mr. Rice responded: “I think you will come within the same rule as officers at the United States forts; their property is not taxed.” The Chippewa Indians in Minnesota, H.R. Ex. Doc. No. 247, at 93 (1890). Individuals from other tribes were present during this colloquy. Id. Cases involving other bands and other legislation have suggested that the land might only be free from taxation during the original trust period, however. Mahnomen County, Minn. v. United States, 319 U.S. 474, 480, 63 S.Ct. 1254, 1258, 87 L.Ed. 1527 (1943) (Murphy, J., dissenting) (land allotted to Mahnomen County Band of Chippewa Indians under Clapp Act exempt from taxation for twenty-five years); United States v. Spaeth, 24 F.Supp. 465, 469 (D.Minn.1938) (land allotted to a White Earth Chippewa Indian under Clapp Act exempt from taxation for twenty-five years).

The Nelson Act disposed of reservation land in three ways. The allotment of land to individual Indians under § 3 of the Nelson Act was done in conformity with the GAA, and Leech Lake tribal members were allotted land either within the Leech Lake reservation or within the reservation of the White Earth Band of Chippewa Indians, which is also in northern Minnesota. The rest of the land was made available to the general public. Some was sold under §§ 4 and 5, the pine lands provisions, and the rest was sold under § 6 pursuant to the Homestead Act, eh. 75,12 Stat. 392 (1862).

Federal Indian policy changed substantially once again in 1934 with the passage of the Indian Reorganization Act (IRA), ch. 576, 48 Stat. 984 (1934) (codified as amended at 25 U.S.C. §§ 461-479 (1996)). The IRA reestablished federal recognition of Indian tribes, and while it did not repeal allotment statutes such as the Nelson Act, it ended the allotment policy and sought to reverse the erosion of the tribal land base by extending indefinitely the trust period for all land held by the United States in trust for Indian tribes. 25 U.S.C. §§ 461-462. The Band is governed in part by a constitution adopted by the Minnesota Chippewa Tribes pursuant to the IRA. See § 476.

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Related

Thompson v. County of Franklin
987 F. Supp. 111 (N.D. New York, 1997)
Leech Lake Band Of Chippewa Indians v. Cass County
108 F.3d 820 (Eighth Circuit, 1997)

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