Seneca Nation of Indians v. New York

Citations: 213 F.R.D. 131; 2003 U.S. Dist. LEXIS 2348; 2003 WL 359727Docket: No. 85-CV-411C

Court: District Court, W.D. New York; February 6, 2003; Federal District Court

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The Seneca-Cayuga Tribe of Oklahoma filed a motion to intervene as of right under Rule 24(a)(2) of the Federal Rules of Civil Procedure, or alternatively for joinder as a necessary party under Rule 19(a). The motion was opposed by the Seneca Nation of Indians, the United States as plaintiff-intervenor, and the State of New York, with oral arguments heard on January 21, 2003. The court denied the motion. 

The underlying case involves the Seneca Nation of Indians' 1985 lawsuit against the State of New York concerning property interests in Cuba Lake and adjacent lands within the historic bounds of the Seneca Nation’s Oil Spring Reservation. After extensive discovery and unsuccessful settlement negotiations, the United States was permitted to intervene in 1998, seeking enforcement of the federal Nonintercourse Act. The court granted summary judgment in favor of the plaintiffs in 1998, concluding that the State unlawfully extinguished Indian title in 1858.

The Seneca-Cayuga Tribe claims to be a successor-in-interest to the Historic Seneca Nation, asserting an interest in the Oil Spring Reservation lands based on the 1794 Treaty of Canandaigua. However, this claim is challenged by the existing parties, who argue against the legitimacy of the Tribe's asserted interest and oppose its intervention or joinder. The Seneca-Cayuga Tribe's motion for intervention is assessed under the standards of Rule 24(a)(2), which allows intervention when the applicant has a significant interest in the action that may be impaired by its outcome, provided that this interest is not adequately represented by current parties.

The applicant for intervention in a legal action must fulfill four criteria: (1) timely filing of the application, (2) a legally protectable interest in the action, (3) demonstration that this interest may be impaired by the outcome, and (4) evidence that the interest is inadequately protected by the existing parties. Failure to meet any of these requirements is grounds for denial of the application. The proposed intervenor's interest must be 'direct, substantial, and legally protectable.' Moreover, intervention should not introduce collateral issues into the existing action.

The timeliness of the application is evaluated at the trial court's discretion, considering factors such as the applicant's notice of interest, potential prejudice to existing parties from delays, potential prejudice to the applicant if denied, and any unusual circumstances affecting timeliness. 

In this case, the Seneca-Cayuga Tribe argues that it only recently became aware of the claims involved, as indicated by Chief LeRoy Howard's term beginning in June 2001. However, this claim is contradicted by the Tribe's longstanding involvement in disputes over the Oil Spring Reservation Lands, dating back to 1924 with multiple proceedings involving the Indian Claims Commission and the Court of Claims, culminating in a 1965 decision favoring the State. Attorney Paul G. Reilly represented both the Seneca Nation and the Seneca-Cayuga Tribe in various related litigations, which further undermines the Tribe's assertion of recent discovery regarding the claims.

In 1982, Congress enacted a statute of limitations for Indian land claims under 28 U.S.C. 2415, mandating the Department of the Interior to publish a list of potential claims from Indian tribes, including a boundary encroachment claim by the Seneca Nation regarding the Oil Springs Reservation published on March 31, 1983. By 1985, the Seneca-Cayuga Tribe had intervened in a federal land claim lawsuit filed by the Cayuga Indian Nation against New York, asserting its status as a successor-in-interest. A July 1999 ruling in the Cayuga case referenced prior decisions regarding the Eleventh Amendment's immunity for state officials, with the Seneca-Cayuga Tribe represented by Glenn M. Feldman, Esq. The tribe's claim of not receiving notice of its interest until June 2001 is deemed untenable, given its long-standing awareness of tribal land issues in New York, particularly regarding the Oil Springs Reservation. The tribe delayed filing a motion until November 2002, despite the historical context. 

Contrasting its situation with the Oneida Indian Nation case, where a late intervention was permitted without prejudice to existing parties due to the case’s early stage, this ongoing case has progressed significantly with completed discovery and motion practice. The introduction of a new party at this stage could jeopardize settlement efforts, as the existing parties contest the Seneca-Cayuga Tribe's claim of successor-in-interest, which would require additional discovery and legal proceedings, disrupting the established litigation process.

The Seneca-Cayuga Tribe asserts that its intervention is necessary to protect its interests under the Treaty of Canandaigua, claiming that failure to intervene would impede its rights and disrupt the ongoing mediation, leading to unnecessary litigation costs. However, the existing parties dispute the Tribe's legitimacy in this matter, indicating they would challenge the Tribe's claims if intervention is permitted. The court finds the Tribe’s request for intervention untimely, noting that it has only recently sought to assert its rights related to a two-hundred-ten-year-old treaty in a case nearing resolution after seventeen years.

To qualify for intervention as of right, the Tribe must demonstrate a legally protectable interest that could be impaired by the case's outcome and that such interest is not adequately represented by existing parties. The Tribe argues its interest is direct and substantial, but existing parties, including the Seneca Nation and the State of New York, contest this assertion. They argue that the Tribe is politically distinct from the historic Seneca Nation, and thus lacks standing. Additionally, the State raises concerns regarding Eleventh Amendment immunity, suggesting that claims made by the Tribe may not align with those asserted by the United States, necessitating further legal considerations. The court emphasizes that the merits of the Tribe's claims cannot be evaluated during the intervention motion itself.

The applicant's allegations must be accepted as true for the motion to intervene, without addressing the merits of the case. Determining the Seneca-Cayuga Tribe's legitimate interest in the Cuba Lake lands would necessitate extensive litigation beyond the current remedy for the State's unlawful acquisition. Given the parties' significant investment in mediation, the court finds the intervention application untimely, avoiding questions about the Tribe's legal interest or potential impairment, which would require examination of the merits of their claims.

Regarding the Seneca-Cayuga Tribe's motion for joinder as a necessary party under Fed. R. Civ. P. 19, the court must assess if the absent party is necessary based on two criteria: whether complete relief can be granted among existing parties in their absence or if the absence would impair the person's ability to protect their interest or risk inconsistent obligations. If deemed necessary, the court evaluates whether the party is indispensable, considering factors such as potential prejudice, the ability to mitigate prejudice through judgment provisions, the adequacy of a judgment rendered without the party, and whether the plaintiff would have an adequate remedy if the action were dismissed due to nonjoinder. The court only needs to determine necessity under Rule 19(a) before addressing indispensability under Rule 19(b), and 'complete relief' refers to relief among existing parties, not involving the absent party.

The court concludes that the Seneca Nation and the United States can obtain full relief in their case against the defendants without the need for the Seneca-Cayuga Tribe to be joined as a party. The plaintiffs have already received the declaratory relief sought, confirming that the State violated the Nonintercourse Act in acquiring disputed Oil Spring lands. The Seneca-Cayuga Tribe did not contribute to this relief and has not demonstrated that its presence is necessary for effective legal or equitable remedies. Citing Heckman v. United States, the court states that the United States is best positioned to represent tribal interests in matters concerning the alienation of Indian lands, making the Seneca-Cayuga Tribe's involvement unnecessary.

Additionally, under Rule 19(a)(2), the Tribe failed to show that the case's outcome without its presence would impair its interests or risk inconsistent obligations for the current parties. The court emphasizes the potential prejudice to existing parties, who have invested considerable resources into the litigation, and therefore denies the Seneca-Cayuga Tribe's motion for intervention or joinder. 

The document also references past developments in the case, including the Seneca Nation's efforts to add private defendants and the withdrawal of the Attorney General as counsel due to a conflict of interest. It further provides historical context regarding the Seneca-Cayuga Tribe's ancestors, the Mingoes, affirming their status as independent bands by the late 18th century, separate from the Six Nations of New York.