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The Indian Trust Fund Management Reform Act (1994 Act), Pub. L. No. 103-412, § 102 (1994), makes clear that the Interior Secretary owes Individual Indian Money trust beneficiaries an accounting for all funds held in trust by the United States for the benefit of an Indian tribe or an individual Indian which are deposited or invested pursuant to the Act of June 24, 1938. 25 U.S.C.S. § 4011(a). "All funds" means all funds, irrespective of when they were deposited (or at least so long as they were deposited after the Act of June 24, 1938). Therefore, the 1994 Act reaffirms the government's preexisting fiduciary duty to perform a complete historical accounting of trust fund assets.
Appellees, beneficiaries of Individual Indian Money trust accounts, filed a class-action suit to compel performance of trust obligations. Appellees alleged that the federal government's trustee-delegates, including the Secretaries of the Interior and Treasury, breached the fiduciary duties owed to appellees by mismanaging the trust accounts. The district court found that the federal government had breached some of the fiduciary duties owed to appellees. The district court further retained jurisdiction and ordered appellants to file quarterly reports detailing steps taken in fulfillment of their duties. Although the decision did not resolve every issue raised by plaintiffs, the district court certified the order for interlocutory appeal. Appellants challenge the district court's delineation of their trust obligations and assert that the district court exceeded its authority in ordering equitable relief for appellees.
Did the district court exceed its authority in ordering equitable relief for appellees?
While the district court mischaracterized some specific actions as material breaches, the appellate court affirmed the order because appellants' failure to take reasonable steps toward the discharge of their trust obligations constituted a breach of their fiduciary duties. Appellants failed to provide an accurate accounting of trust accounts. Appellants unreasonably delayed the discharge of their fiduciary obligations. The district court did not exceed its authority in ordering equitable relief for appellees.