Law School Case Brief
Seminole Nation v. United States - 316 U.S. 286, 62 S. Ct. 1049 (1942)
The text of § 19 of the Curtis Act, 30 Stat. 495, 502, and its legislative history demonstrate that it prohibits only payments to tribal officers which are for disbursement -- i.e., payments to be distributed by them to members of the tribe. Section 19 prohibits payment by the Government to the tribal treasurer only when such payments are to be distributed by him to members of the tribe. It has no application to money earmarked for educational or tribal purposes, and money intended for any purpose the tribe may designate.
The Seminole Nation filed an action against the United States, asserting five claims that alleged violation of Article VIII of the Treaty of August 7, 1856, whereby the Government undertook to provide a certain sum annually for 10 years, to be used for certain purposes, to wit: (i) support of schools; (ii) construction of suitable agency buildings; and (iii) establishment of a trust fund for the Seminole Nation. According to the Seminole Nation, however, the funds were diverted to the clothing and feeding of refugee Indians. The U.S. Court of Claims dismissed the petition because it found that the United States was entitled to gratuity offsets that exceeded the claims allowed against it. The Seminole Nation sought certiorari review.
Did the U.S. Court of Claims err in dismissing the Seminole Nation’s claim?
Yes, in certain aspects.
The United States Supreme Court reversed the dismissal of the Seminole Nation's petition and remanded the case to the lower court for consideration of the Government's fiduciary duty to the Seminole Nation. The Court affirmed the judgment with respect to Claims One, Three, and Four of the Seminole Nation's petition. With respect to Claim One, the Court determined that the Seminole Nation released its claim by a subsequent treaty. With respect to Claim Three, the Court surmised that the Government satisfied the treaty's requirement to support the Seminole Nation's schools because the schools actually received the benefit of money paid to the tribal treasurer. The Court rejected Claim Four because the Government fulfilled the treaty requirement for the construction of an agency building. With respect to Claims Two and Five, the Court remanded the case to the U.S. Court of Claims because the lower court did not make any factual findings regarding the Government's breach of fiduciary duty growing out of its treaty obligations. The Court reasoned that the Government's disbursement of money to satisfy treaty obligations to representatives of the Seminole Nation with the knowledge that they were faithless to their own people would constitute a clear breach of the Government's fiduciary obligation.
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