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Karuk Tribe of California v. Carol McConnell Ammon, Leslie Ammon, Elsie McCovey Bacon, Julia Lauretta Bartow, Ollie Roberts Foseide, Bonita Bacon Green, Janice M. Green, Dorothy Williams Haberman, Richard L. Haberman, Evelina Hoffman, Mary Gist Jackson, Martin Kinder, Sr., Rachel L. Knight, Ernest Lewis, Jr., Annie Mitchell Love, Ardith McConnell Michael McConnell Robert B. McConnell Walter C. McKinnon Thelma W. McLaughlin Steven J. Metcalfe, Edward E. Mitchell, Veta Gillespie Mitchell, Gertrude v. Mollier, Edward Moore David E. O'neill, Herbert L. O'neill, Barbara E. Orcutt, Lawrence E. Orcutt, David Eric Severns, Maria E. Tripp, and Kathryn Ichelson Wild,plaintiffs-Appellants, and Yurok Indian Tribe v. United States, and Hoopa Valley Tribe

Citation: 209 F.3d 1366Docket: 99-5002

Court: Court of Appeals for the Federal Circuit; April 18, 2000; Federal Appellate Court

Narrative Opinion Summary

The case involves an appeal by the Karuk Tribe, the Yurok Indian Tribe, and individual plaintiffs against the United States and the Hoopa Valley Tribe concerning land rights and revenue allocation from the Hoopa Valley Indian Reservation. The plaintiffs allege that the Hoopa-Yurok Settlement Act of 1988 constituted a taking of their property rights in violation of the Fifth Amendment. The Act restructured the Hoopa Valley Reservation, creating separate areas for the Hoopa and Yurok Tribes and reallocating timber revenues exclusively to the Hoopa Tribe. The United States Court of Federal Claims ruled in favor of the United States, finding that the plaintiffs lacked a vested, compensable property interest. The Federal Circuit upheld this decision, concluding that the 1864 Act, under which the original reservation was established, did not grant explicit vested rights to the plaintiffs. The court emphasized that only Congressional acts can confer permanent occupancy rights and that historical executive orders and legislative acts did not establish compensable interests. Furthermore, the 1927 Indian Mineral Leasing Act was interpreted as allowing resource revenue allocation without conferring land title. The appellate court affirmed the lower court's judgment, requiring each party to bear its own costs.

Legal Issues Addressed

Congressional Authority Over Reservation Lands

Application: Congress retains the authority to terminate reservations and reassign land rights, and only a congressional act can grant permanent occupancy rights.

Reasoning: Only Congress has the authority to establish rules regarding U.S. territories and property, and only a congressional act can grant permanent occupancy rights, as opposed to mere permissive occupancy.

Executive Orders and Indian Land Rights

Application: The court found that executive orders establishing reservations do not confer permanent rights without explicit congressional authorization.

Reasoning: An Indian reservation created by presidential order does not confer rights beyond what Congress or the President allows.

Impact of the 1927 Act on Indian Land Rights

Application: The Indian Mineral Leasing Act of 1927 does not grant title to lands but permits allocation of proceeds from resource extraction to tribes.

Reasoning: The 1927 Act allocates proceeds from oil and gas leases to tribes but does not itself grant title to the lands.

Indian Property Rights Under the Fifth Amendment

Application: The court determined that the plaintiffs do not possess compensable property interests under the Fifth Amendment as the 1864 Act did not create vested rights.

Reasoning: The court evaluates the rights conferred by the 1864 Act, noting that while Congress can delegate land to Indians, the Act does not explicitly create vested interests for them.

Settlement Act and Allocation of Timber Revenues

Application: The Hoopa-Yurok Settlement Act allocated timber revenues exclusively to the Hoopa Valley Tribe, superseding previous rulings that allowed all reservation Indians to share in these revenues.

Reasoning: The Settlement Act later superseded these rulings, establishing a new Hoopa Valley Reservation and directing that timber revenues from the square be allocated exclusively to the Hoopa Valley Tribe.