Tanner-Brown v. De La Vega

CourtDistrict Court, District of Columbia
DecidedSeptember 24, 2025
DocketCivil Action No. 2021-0565
StatusPublished

This text of Tanner-Brown v. De La Vega (Tanner-Brown v. De La Vega) is published on Counsel Stack Legal Research, covering District Court, District of Columbia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Tanner-Brown v. De La Vega, (D.D.C. 2025).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

LEATRICE TANNER-BROWN, et al., : : Plaintiffs, : Civil Action No.: 21-565 (RC) : v. : Re Document No.: 46 : DOUG BURGUM, : Secretary of the Interior, et al., : : Defendants. :

MEMORANDUM OPINION

GRANTING DEFENDANTS’ MOTION TO DISMISS

I. INTRODUCTION

Plaintiffs Leatrice Tanner-Brown and the Harvest Institute Freedman Federation, LLC

(“HIFF”) filed this putative class action against the Secretary of the United States Department of

the Interior and the Assistant Secretary for Indian Affairs at the Interior Department, in their

official capacities (“Defendants”), 1 seeking accountings related to land that was allotted to the

minor children of emancipated slaves of Native American tribes. Plaintiffs allege breaches of

trust and fiduciary duties, and seek various remedies, including declaratory and injunctive relief.

This Court previously dismissed Plaintiffs’ claims for lack of standing. The D.C. Circuit

affirmed that decision as to HIFF, but reversed as to Tanner-Brown. On remand, Plaintiffs

amended their Complaint, and Defendants have moved to dismiss under Federal Rules of Civil

Procedure 12(b)(1) and 12(b)(6). This Court concludes, once again, that HIFF lacks

1 Pursuant to Federal Rule of Civil Procedure 25(d), these officials have been substituted for their successors. associational standing. And on the merits, the Court finds that Tanner-Brown failed to plead a

plausible claim that Defendants owed the alleged trust or fiduciary duties. Accordingly, the

Court grants Defendants’ motion to dismiss.

II. BACKGROUND

As this is the Court’s third opinion in this case, it draws from the historical background

described in its previous opinions because these alleged facts have not changed. During the Civil

War, the so-called “Five Civilized Tribes” (i.e., the Seminole, Cherokee, Choctaw, Creek, and

Chickasaw Tribes) kept slaves and allied with the Confederacy. Tanner-Brown v. Haaland

(“Tanner-Brown I”), No. 21-cv-565, 2022 WL 2643556, at *1 (D.D.C. July 8, 2022); First Am.

Compl. (“FAC”) ¶ 19 n.1, ECF No. 43-2. Beginning in 1866, following the defeat of the

Confederacy, the United States entered into a series of treaties and agreements with the Five

Civilized Tribes that, among other things, emancipated the Tribes’ slaves (known as the

“Freedmen”) and provided them with certain rights. See Tanner-Brown I, 2022 WL 2643556,

at *1. In 1898, Congress enacted the Curtis Act, 30 Stat. 495, which allotted the land of the Five

Tribes with certain restrictions to groups of individuals who had historically been enslaved.

Tanner-Brown v. Haaland (“Tanner-Brown III”), 105 F.4th 437, 441 (D.C. Cir. 2024).

The present lawsuit “is based on the provisions of Section 6 of the Act of May 27, 1908,

3[5] Stat. 312,” which the Court refers to as the “1908 Act.” FAC ¶ 19. Section 2 of the 1908

Act “provides that lands ‘from which restrictions have not been removed may be leased’ by the

adult allottee or, if the allottee is a ‘minor or incompetent,’ by a ‘guardian or curator’ on the

allottee’s behalf.” Tanner-Brown III, 105 F.4th at 441 (quoting 1908 Act § 2). Section 6 of the

1908 Act provides in relevant part:

That the persons and property of minor allottees of the Five Civilized Tribes shall, except as otherwise specifically provided by law, be subject to the jurisdiction of

2 the probate courts of the State of Oklahoma. The Secretary of the Interior is hereby empowered, under rules and regulations to be prescribed by him, to appoint such local representatives within the State of Oklahoma who shall be citizens of that State or now domiciled therein as he may deem necessary to inquire into and investigate the conduct of guardians or curators having in charge the estate of such minors, and whenever such representative or representatives of the Secretary of the Interior shall be of [the] opinion that the estate of any minor is not being properly cared for by the guardian or curator, or that the same is in any manner being dissipated or wasted or being permitted to deteriorate in value by reason of negligence or carelessness or incompetency of the guardian or curator, said representative or representatives of the Secretary of the Interior shall have power and it shall be their duty to report said matter in full to the proper probate court and take the necessary steps to have such matter fully investigated, and go to the further extent of prosecuting any necessary remedy, either civil or criminal, or both, to preserve the property and protect the interests of said minor allottees; and it shall be the further duty of such representative or representatives to make full and complete reports to the Secretary of the Interior. All such reports, either to the Secretary of the Interior or to the proper probate court, shall become public records and subject to the inspection and examination of the public, and the necessary court fees shall be allowed against the estates of said minors. The probate courts may, in their discretion appoint any such representative of the Secretary of the Interior as guardian or curator for such minors, without fee or charge.

And said representatives of the Secretary of the Interior are further authorized, and it is made their duty, to counsel and advise all allottees, adult or minor, having restricted lands of all of their legal rights with reference to their restricted lands, without charge, and to advise them in the preparation of all leases authorized by law to be made, and at the request of any allottee having restricted land he shall, without charge, except the necessary court and recording fees and expenses, if any, in the name of the allottee, take such steps as may be necessary, including bringing any such suit or suits and the prosecution and appeal thereof, to cancel and annul any deed, conveyance, mortgage, lease, contract to sell, power of attorney, or any other encumbrance of any kind or character, made or attempted to be made or executed in violation of this Act or any other Act of Congress, and to take all steps necessary to assist said allottees in acquiring and retaining possession of their restricted lands.

1908 Act § 6 (emphases added). 2

2 “The Supreme Court has held that Sections 2 and 6 of the 1908 Act apply to the allotments of minors, notwithstanding the language in Section 1 removing restrictions from the allotments held by minor Freedmen.” Tanner-Brown III, 105 F.4th at 442 (citing Truskett v. Closser, 236 U.S. 223, 229 (1915)).

3 Tanner-Brown alleges that she is the personal representative of the estate of her

grandfather, George Curls, a Cherokee Freedman Allottee who was born to former Cherokee

slave parents in Indian Country, Oklahoma, in 1897. FAC ¶ 33. Curls received 60 acres of

allotments from the Cherokee Tribe under the Curtis Act on December 5, 1910. Id. ¶ 35. At that

time, Curls was a 13-year-old minor. Id.

HIFF is an Ohio limited liability company formed for the purpose of vindicating the

rights of the estates of Freedmen minors owed fiduciary duties by Defendants under the 1908

Act. Id. ¶ 37. HIFF alleges that its “membership is comprised of persons with African and

Native American ancestry,” including “several representatives of Freedmen minor estates.” Id.

“Tanner-Brown and HIFF have filed multiple lawsuits over the past decade on behalf of

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