United States v. Seminole Nation

Citations: 299 U.S. 417; 57 S. Ct. 283; 81 L. Ed. 316; 1937 U.S. LEXIS 7Docket: 172

Court: Supreme Court of the United States; January 4, 1937; Federal Supreme Court; Federal Appellate Court

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The case United States v. Seminole Nation addresses procedural aspects of claims against the United States within the Court of Claims. The Court noted that the Judicial Code allows litigants to apply for a new trial as a matter of right (Jud. Code 175, 28 U.S.C.A. 282). A 1924 Act of Congress permitted the Seminole Nation to pursue claims against the U.S., establishing a five-year statute of limitations for filing suits. Subsequent resolutions extended the time frame for initiating claims. The Seminole Nation filed a petition in 1930 regarding claims arising post-1898 and sought to amend this complaint in 1934, although the statute of limitations had already elapsed.

In December 1935, the Court ruled in favor of the Seminole Nation for over $1.3 million. The U.S. contended that the petition for a writ of certiorari was untimely, as it was filed more than three months after the judgment. The U.S. had initially filed a motion for a new trial, which was denied, and later sought permission to file a second motion. The timing of this second motion's filing and whether it was valid under the relevant statutes was contested, particularly regarding whether it paused the deadline for certiorari. The Court clarified that motions for a new trial must be filed within 60 days unless authorized under section 282, which allows for a new trial if evidence suggests fraud or injustice against the U.S.

Motions under section 282 do not require court permission for filing, allowing defendants to request a new trial as a right. The record lacks evidence indicating that the United States sought or received court permission for its motion, which is unnecessary under the statute. Therefore, the second motion was considered improperly filed under a rule requiring leave, rather than as authorized by the statute. The three-month period for filing a review application does not begin until the court resolves a timely filed new trial motion. The jurisdiction of the lower court was restricted to claims filed within the time frame consented to by the United States, meaning any unalleged causes of action cannot be enforced. The amended petition was not timely, thus failing to bring any causes of action within the court's jurisdiction. Judgments cannot be upheld for claims not present in the original petition or for findings unsupported by clear, definitive evidence.

The petition outlines the following key points: 

1. Jurisdiction is established based on a specific act.
2. The plaintiff was the owner of trust funds managed by the defendant under various treaties and agreements, with interest payments due to the national treasurer of the plaintiff.
3. Following the enactment of the Curtis Act on June 28, 1898, the defendant impounded the plaintiff's funds, ceased payments to the national treasurer, and began unauthorized expenditures of these funds.
4. The Curtis Act only authorized disbursement under section 19, and subsequent congressional acts did not provide authority for the expenditures in question.
5. The defendant has violated its trustee duties and the plaintiff's rights under the treaties and agreements by spending significant amounts of the trust funds without congressional authority since July 1, 1898.
6. The petition requests that the defendant disclose its expenditures, including purposes, dates, and legal authority, and seeks a judgment for amounts spent without legal authority, including interest at 6%.
7. The petition is limited to claims arising after July 1, 1898, and does not seek recovery for the failure to pay funds to the national treasurer or the Seminoles.
8. An amended petition, although submitted too late to add new causes of action, provides useful details about the claims in the original petition, which include thirteen claims, ten of which are partially included in the judgment.
9. A detailed breakdown of amounts claimed in the amended petition correlates with specific findings and judgments.

Overall, the petition emphasizes unauthorized expenditure of trust funds by the defendant, seeking accountability and restitution based on the established legal framework.

The document addresses the disallowance of certain claims and the deductions required from the judgment in a legal case. 

- The amount initially claimed in an amended petition, totaling $66,247.37, was not included in proposed findings of fact.
- The lower court rejected items 2, 6, and 10, as well as portions of items 5, 7, and 13, with the plaintiff not seeking review. The defendant's appeal does not cover items 11, 12, or 13.
- Items 1, 4, and 7 are outside the time frame of the original petition (July 1, 1898, to the suit's commencement) and lack inclusion in any cause of action for that period, necessitating their deduction from the judgment.
- Item 3, amounting to $154,551.28, is part of a $304,551.28 claim. However, since item 2 ($150,000) was disallowed, and the findings indicate that interest from certain years was neither disbursed to tribe members nor paid to the treasurer, $92,051.28 must be deducted from the judgment. Additionally, as the suit focuses on funds that were illegally disbursed, item 3 is eliminated from the judgment.
- Item 5, totaling $90,597.20, pertains to interest on the permanent school fund from the Treaty of March 21, 1866. The judgment inaccurately includes $3,097.20 in interest accrued after July 1, 1898, as well as payments made before the Curtis Act. Thus, these amounts must be excluded from the judgment.
- Item 8, totaling $864,702.58, stems from claims that following the Curtis Act, the defendant improperly managed and disbursed funds contrary to the Act's provisions, establishing the defendant's liability for this amount.

The claim regarding the defendant's refusal to make payments to the tribal treasurer is not part of the original petition, which failed to establish a foundation for the claim and effectively excluded it. The judgment related to this item contradicts the allegations in the original petition, and the plaintiff cannot recover any part of it. 

Item 9, amounting to $154,455.30, is sufficiently alleged in the original petition. It relates to the Original Seminole Agreement, ratified on July 1, 1898, which required that $500,000 be set aside as a permanent school fund, held by the United States at 5% interest. The defendant unlawfully disbursed $154,455.30 from this fund. The court found that prior disbursements by the Secretary of the Interior from the fund in 1920 and 1921, totaling $32,445.56 for per capita payments and $121,519.52 for education, were unauthorized by any act of Congress, thus deeming them illegal. Consequently, the plaintiff is entitled to recover this amount.

Congress anticipated the termination of tribal government as early as 1898. The Act of March 3, 1903, indicated that tribal existence would cease after March 4, 1906, but subsequent resolutions and acts extended tribal status until all property was distributed to individual members. Congress authorized the Secretary of the Interior to manage and liquidate tribal assets, with distributions proceeding under Congressional direction. By 1918, the need for a permanent school fund had significantly diminished, coinciding with the appropriations for the Bureau of Indian Affairs that facilitated the contested per capita payments.

At a hearing before the House Committee on Indian Affairs, the Bureau reported that one Seminole Academy had closed, while the other continued operating, with most pupils having access to public school privileges. Consequently, the Bureau recommended that Congress authorize the Secretary of the Interior to disburse up to $100 per capita from the Seminole school fund to eligible enrolled members or their heirs, under regulations set by the Secretary. The act contained a proviso that no tribal funds could be spent without specific Congressional appropriation, except for authorized payments like the equalization of allotments.

Regulations enacted in 1918 mandated that disbursements would continue until all claims were settled or further departmental orders were issued. While the plaintiff does not dispute the authorization for per capita payments under section 18 of the 1918 appropriation act, it argues that this authority expired after the fiscal year ending June 30, 1919. The payments were viewed as part of a distribution plan for tribal property, without any specified deadline for completion. The provisions in the appropriations for fiscal years 1920 and 1921 sufficiently supported the payments made. 

The Secretary's regulations indicated that withheld payments would be disbursed based on the best interests of those owed. The plaintiff's claim for recovery based on untimeliness of payments is deemed without merit, leading to the exclusion of per capita payment amounts from the judgment. Regarding $490.20 disbursed from the school fund for equalization of allotments, the defendant cited a provision from the February 14, 1920 act that restricts expenditure from tribal funds without specific appropriation, except for authorized payments. However, the defendant did not demonstrate that these payments were legally authorized, thus this amount was appropriately included in the judgment.

The sum of $121,519.52, derived from payments for 'Education' between 1922 and 1930, raises the key issue of whether Congress permitted the use of the principal from the permanent school fund for educational purposes. The applicable appropriation acts for those years empowered the Secretary of the Interior to utilize tribal funds to support Seminole schools. It is inferred that Congress was aware that the Seminole school fund had been significantly depleted, rendering the interest insufficient to cover even reduced educational needs. The consistent language used in yearly appropriations suggests Congressional intent to allow expenditures for education from both the interest and the principal of the fund. Consequently, the inclusion of this amount in the judgment is not supported. The judgment is reversed, and the case is remanded to the lower court for further proceedings.

Mr. Justice Stone did not participate in the consideration or decision of this case. The document outlines regulations concerning payments from the United States to tribal governments, stating that no payments shall be made to tribal governments or officers for disbursement; instead, all payments to tribal members are to be directed by the Secretary of the Interior. Per capita payments must be made directly to individuals, and such payments are protected from being used for prior obligations.

Additionally, it specifies that funds belonging to Indian tribes with treaty relations cannot be used outside the purposes authorized by those treaties or specific laws, and appropriated treaty funds cannot be redirected unless legally permitted. The text includes a breakdown of specific treaty funds and legislative acts relevant to appropriations and payments to the Seminole Tribe of Indians, emphasizing that the Secretary of the Interior has the authority to disburse funds and may withhold payments for restricted Indians under certain conditions. Various acts from 1911 to 1929 are referenced, indicating ongoing legislative activity concerning Indian appropriations.