Court case

Cayuga Indian Nation of New York v. Pataki

The Second Circuit barred the Cayugas' land claim against New York under laches, reversing a $248 million award after the Sherrill decision.

Citation
413 F.3d 266 (2d Cir. 2005), cert. denied, 547 U.S. 1128 (2006)
Court
U.S. Court of Appeals, 2d Cir.
Year
2005
Nations
Cayuga Nation (Haudenosaunee)
Treaty at issue
Conveyances of 1795 and 1807 (64,015 acres); Treaty of Canandaigua (1794)
Holding
Laches bars possessory land claims in the nature of ejectment; vacated a roughly $247.9 million judgment, applying Sherrill broadly. Hall dissented.
Effect on land rights
eroded

What happened

In a 1789 treaty with New York, the Cayugas ceded all their lands to the State except an "Original Reservation" on the shores of the northern end of Cayuga Lake. In the 1794 Treaty of Canandaigua, the United States acknowledged that reservation and promised the land would remain theirs until they chose to sell it. This case involves 64,015 acres of it. The Second Circuit says New York later acquired the land through "treaties" in 1795 and 1807 that the federal government never explicitly ratified. In 1807, for example, the State purchased the Cayugas' remaining three-square-mile parcel for $4,800.

On November 19, 1980, the Cayuga Nation filed suit, later joined by the Seneca-Cayuga Tribe of Oklahoma. They argued the transfers violated the federal Nonintercourse Act, which, the Supreme Court has said, "bars sales of tribal land without the acquiescence of the Federal Government." Defendants included New York State, two counties and a class of landowners. The Northern District of New York agreed on liability and awarded about $248 million in damages and prejudgment interest.

Then the Supreme Court decided City of Sherrill v. Oneida Indian Nation in 2005. It ruled that equitable doctrines such as laches, acquiescence and impossibility can be applied to Indian land claims in appropriate circumstances. The Second Circuit read that to include possessory land claims like this one. It held the claim barred by laches and reversed. Judge Hall dissented in part and concurred in part.

The court began by noting the wrongs alleged "occurred over two hundred years ago, and this action is itself twenty-five years old."

Summarized with AI assistance from 4 sources and checked against their words; not yet reviewed by historians or by the nations. Report an error

What the sources say, and how this was checked

Well supported by the sources below.

  1. We hold that plaintiffs’ possessory land claim is subject to the defense of laches and conclude that the claim must be barred on that basis.Cayuga Indian Nation of New York v. Pataki, 413 F.3d 266 (2d Cir. 2005) (CourtListener)
  2. equitable doctrines, such as laches, acquiescence, and impossibility, can, in appropriate circumstances, be applied to Indian land claimsCayuga Indian Nation of New York v. Pataki, 413 F.3d 266 (2d Cir. 2005) (CourtListener)
  3. This treaty acknowledged the Original Reservation the Cayugas retained in the 1789 treaty with New YorkCayuga Indian Nation of New York v. Pataki, 413 F.3d 266 (2d Cir. 2005) (CourtListener)
  4. In 1807, the State of New York purchased the Cayugas' remaining three-square-mile-parcel for $4,800.Cayuga Indian Nation of New York v. Pataki, 413 F.3d 266 (2d Cir. 2005) (CourtListener)

Research notes. Judge Hall is a district judge sitting by designation. The Supreme Court's denial of certiorari in 2006 (547 U.S. 1128) comes from our data and was not verified here, so it is not stated in the narrative. The Treaty of Canandaigua (1794) is confirmed by this opinion.

Treaty or agreementShapes from the 1899 federal record: approximate, not legal boundaries.

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Connections

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Doctrine applied 3

Nations named 2

Concerns the instrument 1

Policy era 1

Sources

  1. storage.courtlistener.com/pdf/2005/08/01/FOR_THE_SECOND_CIRCUIT_124.pdflegal text copy
Kind
Court case
Confidence
High

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