State v. Lowe

327 N.W.2d 166, 109 Wis. 2d 633, 1982 Wisc. App. LEXIS 4055
CourtCourt of Appeals of Wisconsin
DecidedNovember 16, 1982
Docket81-1975, 81-1976, 81-1977, 81-1978
StatusPublished

This text of 327 N.W.2d 166 (State v. Lowe) is published on Counsel Stack Legal Research, covering Court of Appeals of Wisconsin primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
State v. Lowe, 327 N.W.2d 166, 109 Wis. 2d 633, 1982 Wisc. App. LEXIS 4055 (Wis. Ct. App. 1982).

Opinion

FOLEY, P.J.

Richard Lowe and Kenneth Mosay appeal judgments convicting them of possession of game fish during the closed season and possession of a spear on Big Round Lake, Polk County, Wisconsin, in violation of sec. 29.39, Stats, and Wis. Admin. Code, sec. NR 20.07 (2). As enrolled members of the St. Croix band of Lake Superior Chippewa, we conclude that Lowe and Mosay have the same fishing rights in Big Round Lake that members of the Bad River and Red Cliff bands of Lake Superior Chippewa have in Lake Superior. See State v. Gurnoe, 53 Wis. 2d 390, 407-09, 192 N.W.2d 892, 900-01 (1971). Because the state must therefore prove that it has subject matter jurisdiction before it can convict Lowe and Mosay of the offenses charged, we reverse the judgments and remand these matters for a hearing as provided in State v. Peterson, 98 Wis. 2d 487, 495-96, 297 N.W.2d 52, 55 (Ct. App. 1980). See also State v. Braun, 103 Wis. 2d 617, 630, 309 N.W.2d 875, 881 (Ct. App. 1981).

Treaties and executive orders that do not specifically grant fishing rights to Indians have been interpreted by both the United States and the Wisconsin Supreme Courts to grant certain fishing rights. Alaska Pacific Fisheries v. United States, 248 U.S. 78, 90 (1918); Gurnoe, 53 Wis. 2d at 402, 192 N.W.2 at 897-98. Where there is no specific grant, the court must look to the intent of the parties to the treaty. To determine that in *635 tent, the court must consider the history of the tribe or band. Gurnoe, 53 Wis. 2d at 403, 192 N.W.2d at 898.

The history of the St. Croix band shows that the United States and the band intended that the band have nonexclusive fishing rights in Big Round Lake. The St. Croix band, one of the many bands of Lake Superior Chippewa, has an extensive history of official dealings with the United States government. The first treaty of importance was the Treaty of Prairie du Chien in 1825, 1 through which the United States sought to establish peace between the Chippewa and the Sioux, who had been warring over hunting grounds. By this treaty, the United States recognized title in the St. Croix band to its aboriginal area, including Big Round Lake. Minnesota Chippewa Tribe v. United States, 19 Ind. Cl. Comm. 514 (1968).

The next major treaty to which the St. Croix band was a party was the Treaty of St. Peters in 1837. 2 The United States wanted large areas of Indian land in north central Wisconsin and east central Minnesota because it contained valuable pine timber and because the United States wanted to open the territory for white settlement. See United States v. Bouchard, 464 F. Supp. 1316, 1322 (W.D. Wis. 1978). Although the St. Croix band ceded its land to the United States in this treaty, it reserved the right to hunt, fish, and gather wild rice, at the pleasure of the President of the United States, on the ceded territory. 3 In return, the “United States agreed to pay annuities in the form of goods and money, to distribute money to half-breeds, and to pay some Indian debts to traders.” 4

*636 By the Treaty of La Pointe in 1842, 5 the Lake Superior Chippewa ceded more land to the United States. The St. Croix band was also a party to this treaty. Again, however, the Chippewa reserved the right to hunt and to exercise the other usual privileges of occupancy with respect to the ceded land until such time as the President required them to leave the land. 6

Although President Zachary Taylor attempted to require the Chippewa to leave Wisconsin by issuing an executive order in 1850, the St. Croix band remained in its aboriginal area. The removal effort failed with other Chippewa as well. As a result, the Wisconsin legislature passed a memorial in 1854 requesting that the President rescind his 1850 order and allow the Wisconsin Chippewa to remain in the state. Gurnoe, 53 Wis. 2d at 397, 192 N.W.2d at 895. The Treaty of 1854 followed this memorial.

By the Treaty of 1854, the United States sought to obtain further cession of Chippewa land in Minnesota and also to establish homeland reservations for the Chippewa in Wisconsin. Although reservations were established for various Chippewa bands, the St. Croix band is not listed as a signatory to this treaty, and no provision was made for the St. Croix band. Because they had no reservation, the band members began to refer to themselves as the “Lost Band” and remained in their tribal homelands, surviving as best they could. 7

The band had no further official dealings with the United States until 1909, when the United States Senate held hearings on Indian affairs. Several St. Croix band members testified at these hearings. Their testimony indicated that the band was still living its aboriginal life *637 in its aboriginal area. 8 Following the hearings, the Bureau of Indian Affairs directed the Secretary of the Interior to conduct an investigation of the St. Croix band.

W.M. Wooster conducted the investigation and reported that most of the “lost Chippewa Tribe” belonged to the band of Chief Buck, or Ai-yaw-banse, who signed the Treaty of 1854 as a chief of the Lac Court Orieilles band of Lake Superior Chippewa. 9 Wooster’s preliminary report indicated that most of the St. Croix band members were living as squatters on public lands in Douglas, Burnett, Polk, and Washburn counties. 10 Wooster subsequently reported that the band had a settlement on Big Round Lake in Polk County. 11

Congress responded to the Wooster reports by appropriating money annually between 1919 and 1934 to settle the St. Croix band’s claim for not receiving land under the Treaty of 1854. 12 Then, in 1934, Congress passed the *638 Indian Reorganization Act 13 (IRA) in which it sought to establish a land base for tribes without land. 14 In order to meet this goal, Congress authorized the Secretary of the Interior to acquire land for tribes and also to proclam new Indian reservations. 25 U.S.C.A. §§ 465, 467 (West 1963).

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Related

Alaska Pacific Fisheries v. United States
248 U.S. 78 (Supreme Court, 1918)
United States v. Bouchard
464 F. Supp. 1316 (W.D. Wisconsin, 1978)
State v. Gurnoe
192 N.W.2d 892 (Wisconsin Supreme Court, 1972)
State v. Braun
309 N.W.2d 875 (Court of Appeals of Wisconsin, 1981)
State v. Peterson
297 N.W.2d 52 (Court of Appeals of Wisconsin, 1980)

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Bluebook (online)
327 N.W.2d 166, 109 Wis. 2d 633, 1982 Wisc. App. LEXIS 4055, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-lowe-wisctapp-1982.