Choctaw Nation v. United States

What happened

By the Treaty of September 27, 1830, the Choctaw Nation ceded its lands to the United States. The Choctaws later claimed that the United States had broken that treaty and that they should receive the proceeds of the sale of the ceded lands. In the Treaty of June 22, 1855, the two sides submitted their disputes to the United States Senate, which acted as arbitrator. The Senate's award was later computed by the Secretary of the Interior at $2,981,247.30.

In 1881 Congress authorized the Court of Claims to "take jurisdiction of and try all questions of difference arising out of treaty stipulations with the Choctaw nation" and to review them de novo, meaning from scratch. The Court of Claims found a balance due the Nation of $408,120.32. Both the Nation and the United States appealed.

The Supreme Court reversed. It said that when the United States deals with tribes under its "care and control," its acts and promises are to be interpreted as "justice and reason demand." It held that the Senate's award "furnishes the nearest approximation to the justice and right of the case." The judgment was for $2,981,247.30, subject to the deduction of $250,000 paid under the act of 1861, plus $59,445.32 in unpaid annuities and $68,102 for lands taken in fixing the Arkansas boundary. Chief Justice Waite dissented.

The Court's reading of the 1881 act meant the Senate award, not the Court of Claims' smaller figure, set the measure of what the Choctaws were owed.

Good to know. Dollar figures are as printed in the U.S. Reports, which has small inconsistencies (for example $59,449.32 in an exhibit versus $59,445.32 in the judgment for one annuity).

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