Oglala Sioux Tribe of Pine Ridge Indian Reservation v. Hallett

708 F.2d 326
CourtCourt of Appeals for the Eighth Circuit
DecidedMay 20, 1983
DocketNo. 82-1756
StatusPublished
Cited by5 cases

This text of 708 F.2d 326 (Oglala Sioux Tribe of Pine Ridge Indian Reservation v. Hallett) 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
Oglala Sioux Tribe of Pine Ridge Indian Reservation v. Hallett, 708 F.2d 326 (8th Cir. 1983).

Opinion

HEANEY, Circuit Judge.

The Oglala Sioux Tribe [Tribe] brought this action in the United States District Court for the District of South Dakota seeking declaratory, injunctive, and other appropriate relief from the decision of the Secretary of the Interior [Secretary] approving Richard Tail’s application for fee patents on certain lands within the exterior boundaries of the Pine Ridge Indian Reservation. The Tribe named the Secretary and other persons in the Department of the Interior, in their official capacities, the United States, and Richard Tall as defendants. The district court granted summary [328]*328judgment in favor of all defendants, 540 F.Supp. 503. The Tribe appeals and we affirm.

In March of 1976, Richard Tall, a member of the Tribe, applied to the Bureau of Indian Affairs of the Department of the Interi- or [BIA] for fee patents — in essence, legal title — on three allotments of land held in trust for him by the United States.1 Pursuant to a tribal policy favoring expansion of tribal ownership of land within the reservation, the Tribal Council passed Ordinance 76-05 on May 11, 1976, which the Tribe asserts restricts applications for fee patents on trust lands by Tribe members.2 On May 21,1976, the Pine Ridge Agency of the BIA informed the Tribe’s Executive Committee of Tail’s application, apparently pursuant to 25 C.F.R. § 152.2 (1982),3 which would give the Tribe a reasonable opportunity to purchase the land from Tall prior to the Secretary’s decision whether to grant his application for a patent. The Pine Ridge Agency later denied Tail’s application, on March 23, 1977. Tall appealed to the BIA Area Director in the Aberdeen Area Office, who reversed the decision of the Pine Ridge Agency on May 31, 1978. The Tribe intervened in the administrative proceedings at this point and appealed first to the Commissioner of Indian Affairs and then to the Interior Board of Indian Appeals [IBIA]. The IBIA rendered the final decision of the Department of the Interior on September 7, 1979, holding that “it was not error for the Bureau of Indian Affairs to approve Richard Tail’s fee patent applications.” Administrative Appeal of Oglala Sioux Tribe, 7 I.B.I.A. 188, 211 (1979). The Tribe then filed the instant action in federal district court.

The district court granted summary judgment against the Tribe on May 27, 1982.4 The court held that the Secretary had discretion to approve Tail’s application under 25 U.S.C. § 483 (1976), which was not affected by tribal ordinances to the contrary. Oglala Sioux Tribe of Pine Ridge Indian Reservation v. Hallett, 540 F.Supp. 503, 505 (D.S.D.1982). In addition, the court held that, even if federal statutes and regulations required the Secretary to find that Tall was “competent” prior to approving his application, the Secretary possessed sole discretion to make such a finding, the Tribe might not have standing to question Tail’s competency, the Tribe in fact failed to con[329]*329test Tail s competency before the IBIA, and the administrative record would support a finding that Tall was competent. Id. at 505, 506 & n. 5. Finally, the court found that any special restrictions on the sale of one of the allotments which Tall acquired under the Act of August 8, 1968, Pub.L. No. 90-468, 82 Stat. 663 (1968), did not limit the Secretary’s power to issue a fee patent thereon. Id. at 506.

On appeal, the Tribe’s position is that the Secretary has no authority to issue fee patents except to the Tribe as a matter of federal law and that, even if federal statutes give the Secretary discretion to issue fee patents to individuals, the Secretary is bound in exercising that discretion by the provisions of tribal law. In support of this position, the Tribe raises four main contentions: (1) that the allotments in issue are not held under the provisions of the Indian Reorganization Act of 1934, 25 U.S.C. §§ 461 et seq. (1976 & Supp. IV 1980), and thus are not subject to the award of fee patents under 25 U.S.C. § 483 (1976); (2) that, assuming these allotments are subject to the provisions of section 483, Tall does not intend to sell the land and section 483 applies only when a fee patent is approved pursuant to a sale of trust land; (3) that, even if the Secretary has discretion to issue Tall a fee patent under section 483, the Secretary is bound by Ordinance 76-05 in exercising that discretion; and (4) that the Act of August 8, 1968, Pub.L. No. 90-468, 82 Stat. 663 (1968), requires a sale within ten years of Tail’s acquisition of one allotment which he bought under that act, with a right of first preference in the Tribe to purchase that land, in order to avoid mandatory continuation of the trust on that allotment under 25 U.S.C. § 464 (Supp. IV 1980).5 We disagree with each of these contentions.

The Tribe’s first contention is that 25 U.S.C. § 483 (1976), under which the Secretary approved Tail’s application, does not apply to Tail’s allotments here at issue. Section 483 reads:

The Secretary of the Interior, or his duly authorized representative, is authorized in his discretion, and upon application of the Indian owners, to issue patents in fee, to remove restrictions against alienation, and to approve conveyances, with respect to lands or interests in lands held by individual Indians under the provisions of sections 461, 462, 463, 464, 465, 466 to 470, 471 to 473, 474, 475, 476 to 478, and 479 of this title [the Indian Reorganization Act [330]*330of 1934], or subchapter VIII of this chapter.

Id.

The Tribe claims that the “held * * * under” language in this section indicates that Congress only authorized the Secretary to issue fee patents on lands put in trust for individual allottees after purchase with funds appropriated under Section 5 of the Indian Reorganization Act of 1934. See 25 U.S.C. § 465 (1976). Considering the history and purpose of section 483, we cannot agree.

The allotments at issue in the present case apparently were first awarded near the turn of the century pursuant to the Sioux Agreement of 1889, ch. 405, 25 Stat. 888 (1889). See supra note 1. Federal policy at that time was to allot parcels of reservation land to individual Indians; the individual allottees would eventually obtain legal title to their allotments and no longer be dependent on tribes and reservations for their subsistence. See generally Mattz v. Arnett, 412 U.S. 481, 496-497, 93 S.Ct. 2245, 2253-54, 37 L.Ed.2d 92 (1973). Section 11 of the 1889 agreement provided that, once allotments were made, the Secretary would issue patents in the name of the allottees which the United States would hold in trust for a period of twenty-five years. Sioux Agreement of 1889,

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Yankton Sioux Tribe v. Podhradsky
577 F.3d 951 (Eighth Circuit, 2009)
Wilkinson v. United States
440 F.3d 970 (Eighth Circuit, 2006)

Cite This Page — Counsel Stack

Bluebook (online)
708 F.2d 326, Counsel Stack Legal Research, https://law.counselstack.com/opinion/oglala-sioux-tribe-of-pine-ridge-indian-reservation-v-hallett-ca8-1983.