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Yankton Sioux Tribe, and Its Individual Members, United States of America, on Its Own Behalf and for the Benefit of the Yankton Sioux Tribe, Intervenor v. Matt Gaffey, States Attorney of Charles Mix County Herman Peters, Member of the Charles Mix, South Dakota,.counnty Commission Bruce Bakken,member of the Charles Mix, South Dakota, County Commission Jack Soulek, Member of the Charles Mix, South Dakota, County Commission, William Janklow, Governor of South Dakota Mark W. Barnett, Attorney General of South Dakota,defendants. Gary Beeson, Landowner City of Dante City of Geddes City of Lake Andes City of Pickstown City of Platte City of Ravinia City of Wagner Harvey P. Weisser, Doing Business as Weisser Oil Co., Inc., Individually, Amici on Behalf Of

Citation: 188 F.3d 1010Docket: 1010

Court: Court of Appeals for the Eighth Circuit; August 31, 1999; Federal Appellate Court

Narrative Opinion Summary

The Yankton Sioux Tribe v. Matt Gaffey et al. case in the Eighth Circuit Court of Appeals involves the Yankton Sioux Tribe's challenge to state criminal jurisdiction over tribal members on nonceded lands within the original reservation boundaries established by an 1858 treaty. Following the Supreme Court's decision in South Dakota v. Yankton Sioux Tribe, which held that the reservation was diminished by lands ceded under the 1894 Act, the district court ruled in favor of the Tribe, asserting the reservation's boundaries remain intact. The district court issued injunctions against state jurisdiction on reserved lands, but appeals by the State of South Dakota and others led to a reversal of this decision. The appellate court concluded that the reservation was diminished but not disestablished, and the original boundaries do not delineate Indian country from state jurisdiction. The case's complexity arises from differing interpretations of the 1894 Act's impact on jurisdiction and reservation boundaries. The court vacated the district court's injunctions and remanded the case for further proceedings, highlighting the need for clear congressional intent to alter reservation status. The decision underscores the significance of jurisdictional history and congressional actions in determining the status of tribal lands.

Legal Issues Addressed

Congressional Intent in Reservation Status

Application: The court analyzed congressional intent regarding the 1894 Act, determining that there was no clear intent to disestablish the reservation for nonceded lands.

Reasoning: Congressional intent is critical in determining whether the 1894 Act changed the status of nonceded lands.

Federal and State Jurisdiction

Application: The court considered the division of jurisdictional authority between federal and state governments over lands within the Yankton Sioux Reservation, relying on historical jurisdictional practices.

Reasoning: Longstanding divisions of jurisdictional authority carry significant weight in boundary disputes.

Jurisdiction over Indian Lands

Application: The court examined jurisdiction over nonceded lands within the original reservation boundaries, determining the extent of the Tribe's jurisdiction based on the 1894 Act and subsequent legal interpretations.

Reasoning: Jurisdiction over nonceded lands within the original reservation boundaries is the central issue, specifically regarding the extent of the Tribe's jurisdiction.

Reservation Diminishment and Disestablishment

Application: The court concluded that the Yankton Sioux Reservation had not been disestablished but was diminished, affecting the jurisdiction over lands that have exited trust status.

Reasoning: As a result, it is concluded that the Yankton Sioux Reservation has not been disestablished but has been diminished due to the loss of allotted lands that have passed out of Indian hands.