United States v. Sandoval - 231 U.S. 28, 34 S. Ct. 1 (1913)

Rule:

Not only does the Constitution expressly authorize Congress to regulate commerce with the Indian tribes, but long continued legislative and executive usage and an unbroken current of judicial decisions have attributed to the United States as a superior and civilized nation the power and the duty of exercising a fostering care and protection over all dependent Indian communities within its borders, whether within its original territory or territory subsequently acquired, and whether within or without the limits of a State. The power of the General Government over these remnants of a race once powerful, now weak and diminished in numbers, is necessary to their protection, as well as to the safety of those among whom they dwell. It must exist in that government, because it never has existed anywhere else, because the theatre of its exercise is within the geographical limits of the United States, because it has never been denied, and because it alone can enforce its laws on all the tribes. Congress, in pursuance of the long-established policy of the Government, has a right to determine for itself when the guardianship which has been maintained over the Indian shall cease. It is for that body, and not for the courts, to determine when the true interests of the Indian require his release from such condition of tutelage.

Facts:

Sandoval was indicted on a charge that he introduced intoxicating liquor into the Indian pueblos of New Mexico after New Mexico had become a state. Under 36 Stat. 557, New Mexico's statehood was conditioned upon the Indian pueblos being treated as Indian country under 29 Stat. 506. The trial court dismissed the indictment on Sandoval’s demurrer, in which he claimed that the statutes were invalid as applied to the Pueblo Indians and their land because the Pueblos were U.S. citizens who owned their land in fee simple. Thus, Sandoval contended that the legislation usurped the state's police power.

Issue:

Did the Congress have the authority to prohibit the introduction of liquor into the Pueblo land?

Answer:

Yes

Conclusion:

The court held that that although the Pueblo Indians might arguably have been citizens, Congress still had the authority to prohibit the sale of liquor in their territory because they were Indians. Although the Pueblo Indians owned their land in fee, the Court found that it was owned collectively by the Pueblos and that Congress had the authority to prohibit the introduction of liquor into the Pueblo land.