Marriage of Murray v. Murray

3 Am. Tribal Law 25
CourtConfederated Salish & Kootenai Court of Appeals
DecidedDecember 31, 2001
DocketNo. AP-DA-261-87
StatusPublished

This text of 3 Am. Tribal Law 25 (Marriage of Murray v. Murray) is published on Counsel Stack Legal Research, covering Confederated Salish & Kootenai Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Marriage of Murray v. Murray, 3 Am. Tribal Law 25 (salishctapp 2001).

Opinion

OPINION

DESMOND, Justice:

This case presents the question of tribal court jurisdiction, in an action for dissolution of marriage, to order a party to seek from the Bureau of Indian Affairs, (“BIA”), a change in the status of trust property, in accordance with the parties’ property settlement agreement.

This is the second appeal in this matter. In the first, we reversed the Tribal trial court’s entry of a default judgment and remanded the matter for further proceedings. Cause No. AP-DA-161-87, January 20, 2000. This is an appeal of the Tribal trial court’s Order of September 20, 2000, following remand, denying Appellant’s Motion to dismiss for lack of jurisdiction. We affirm the Tribal trial court in accordance with the following.

The case has a lengthy procedural history outlined in our opinion on the first appeal that we will not repeat here. In brief, in 1988, the Tribal trial court dissolved the marriage of Appellant Sandra Murray (“Sandra”) and Appellee Michael Murray (“Michael”), Sandra is a tribal member; Michael is not. In their property settlement agreement, (Ct. Doc. No 9, August 25, 1988), later incorporated in the dissolution decree, the parties agreed to sell the marital trust property and divide the proceeds after all liens were satisfied.

Paragraph IV (1) of the property settlement agreement states in part: “The real property shall be sold without undue delay and both parties shall do whatever is necessary to effectuate the sale of said real property.” The property has not yet been sold, primarily because Sandra has not cooperated in the sale. Michael has attempted to obtain Sandra’s cooperation through a series of court proceedings in both state and tribal court but has been unable to bring about her cooperation.

While Sandra has, at times, participated in efforts to resolve the question of disposition of the marital property, e.g. she took part in an effort to convey the land several years ago, she has not submitted to the BIA, the documents necessary to begin the process of disposing of the property. 25 CFR 121.23. For this reason the Tribal trial court held her in contempt of court in August 1991.

Sandra asserts that the Tribal trial court erred as follows:

(1) the Tribal Court lacks jurisdiction because the United States is a necessary party to an action affecting title to trust property.
(2) Sandra entered into the settlement agreement under duress,
(3) the Tribal trial court’s decision is in effect a lien upon trust property contrary to federal law,
[27]*27(4) the Tribal trial court’s order inequitably distributes the parties’ property.

Turning first to Sandra’s jurisdictional arguments, we find that the Tribal trial court does have jurisdiction to enter the Order from which Sandra has appealed. No doubt exists that the Confederated Salish and Kootenai Tribes possess and exercise broad authority over domestic relations of their members. Federal law has long recognized and supported broad tribal jurisdiction in the area of domestic relations. (“If an Indian tribe has power to regulate the marriage relationships of its members, it necessarily has power to adjudicate, through tribunals established by itself, controversies involving such relationships.” Powers of Indian Tribes, 55 Interior Dec. 14, 56 (1934).) See also, Fisher v. District Court, 424 U.S. 382, 96 S.Ct. 943, 47 L.Ed.2d 106 (1976); Mississippi Band of Choctaw Indians v. Holyfield, 490 U.S. 30, 109 S.Ct. 1597, 104 L.Ed.2d 29 (1989); Sanders v. Robinson, 864 F.2d 630 (9th Cir.1988).

Yet Sandra is correct that federal law limits tribal authority to determine beneficial ownership of trust property.

Indian lands are governed solely by federal law and where legal title to such land is held in trust by the United States, any attempted conveyance or alienation must conform to the requirements of federal law. Alienation of restricted Indian lands can only be effectuated pursuant to congressional authorization and according to the rules and regulations prescribed by the Secretary of the Interior.

Pitts v. Earling, (Cause No, APCV-073-93, December 5, 1994, Citation omitted). See also, §§ 25 U.S.C.464, 483. The BIA has established a process to be followed in order for an owner of trust property to convey trust land, including a conveyance in which the land will be taken out of trust. Here, the Tribal trial court recognized that it does not have jurisdiction over the BIA or its process. But the federal limits on tribal authority over trust property do not preclude the Tribal Court’s actions in this case. Further, Sandra does not, nor could she, challenge the Tribal Court’s jurisdiction over her.

Over twenty years ago, the United States Court of Appeals for the Eighth Circuit faced the question presented here in the case of Conroy v. Conroy, 575 F.2d 175 (1978). Conroy involved the validity of a Tribal marital dissolution decree in which the presiding tribal judge directed one of the parties to apply to the BIA to transfer title to the parties’ trust property to the other party. In the face of challenges legally similar to those presented by Sandra, the Eighth Circuit found the Tribal Court’s action to be within its jurisdiction as a matter of federal law. Id. at 183.

The Conroy case has continuing validity, as shown by a recent decision of the Office of Hearings and Appeals of the Department of Interior that cited Conroy. The Administrative Law Judge held in a probate proceeding that the Crow Tribal Court lacked jurisdiction “to determine the ownership of trust land located on the Crow Reservation between members of the Crow Tribe”. Matter of the Estate of Jesse Hill, Probate No. IP BI 089A 83 (August 24, 2001.) However, the ALJ stated that, “although a Tribal Court cannot change title of trust land, nothing prevents a Tribal Court from ordering an individual to convey a quantity of real property as a means of effectuating property rights. Conroy v. Frizzell, 429 F.Supp. 918 (1977),” (This is the decision that was affirmed in Conroy v. Conroy, 575 F.2d 175.)

[28]*28Sandra asserts that this case should be resolved in her favor under the decision of the Interior Board of Indian Appeals in Sherry Camel v. Assistant Portland, Area Director, Bureau of Indian Affairs., IBIA 91-116-A. We disagree. The facts of the Camel matter are somewhat similar to those in this case but the issue before the IBIA differed from that presented here. In the Camels’ divorce decree, the Tribal trial court ordered the husband to convey his interest in the parties’ jointly-owned trust property by applying to the BIA for the conveyance. Mr. Camel did not go through the BIA process to accomplish this. Mrs. Camel then asked the BIA to carry out the conveyance without Mr.

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Related

Mississippi Band of Choctaw Indians v. Holyfield
490 U.S. 30 (Supreme Court, 1989)
Gerry Conroy v. Evelyn Sybil Conroy
575 F.2d 175 (Eighth Circuit, 1978)
Conroy v. Frizzell
429 F. Supp. 918 (D. South Dakota, 1977)
Sanders v. Robinson
864 F.2d 630 (Ninth Circuit, 1988)

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Bluebook (online)
3 Am. Tribal Law 25, Counsel Stack Legal Research, https://law.counselstack.com/opinion/marriage-of-murray-v-murray-salishctapp-2001.