Court case

Idaho v. United States

The Court held the lakebed and part of the riverbed within the Coeur d'Alene reservation belong to the United States in trust, not Idaho.

Citation
533 U.S. 262 (2001)
Court
U.S. Supreme Court
Year
2001
Nations
Coeur d'Alene Tribe (Schitsu'umsh)
Treaty at issue
Executive order of 1873 and agreement/act of 1889-1891
Effect on land rights
advanced

What happened

The Coeur d'Alene Tribe lived in and about what is now Idaho and traditionally used Lake Coeur d'Alene and the St. Joe River for food, fiber, transportation, recreation and cultural activities. In 1873 the Tribe agreed to give up, for compensation, all claims to its aboriginal lands outside a specified reservation that included part of the river and virtually all of the lake. The agreement required congressional approval. President Grant set the land aside in an 1873 Executive Order anyway, with the reservation's northern boundary running across the lake.

Congress neither ratified the agreement nor compensated the Tribe. The Tribe petitioned for a proper treaty, and Congress authorized negotiations. In 1887 the Tribe agreed to cede its rights to all land except that within the Executive Order reservation, and the Government promised to compensate the Tribe and hold the land forever as Indian land. A new agreement in 1889 had the Tribe cede the reservation's northern portion, including two-thirds of the lake, for compensation. While the ratifying bill was pending in the House, Congress admitted Idaho to the Union in 1890. In 1891 Congress ratified the 1887 and 1889 agreements.

The United States sued Idaho to quiet title to the submerged lands, in trust for the Tribe. The Supreme Court, 5-4, held that the National Government holds title in trust for the Tribe to the lands under the portions of the lake and river within the reservation. Idaho conceded that the Executive Branch had interpreted the 1873 reservation to include submerged lands, and the Court found that Congress recognized the full extent of that reservation and intended to bar passage of title to Idaho.

Summarized with AI assistance from 3 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. The National Government holds title, in trust for the Tribe, to lands underlying portions of Lake Coeur d'Alene and the St. Joe River.Idaho v. United States, 533 U.S. 262 (2001) (U.S. Reports, Library of Congress)
  2. Idaho has conceded that the Executive Branch intended, or interpreted, the 1873 Executive Order reservation to include submerged lands.Idaho v. United States, 533 U.S. 262 (2001) (U.S. Reports, Library of Congress)
  3. In 1891, Congress ratified the 1887 and 1889 agreements.Idaho v. United States, 533 U.S. 262 (2001) (U.S. Reports, Library of Congress)

Research notes. The 5-4 vote is from the U.S. Reports headnote (Souter for the Court, Rehnquist dissenting). Our data's 'Executive order of 1873 and agreement/act of 1889-1891' omits the unratified 1873 agreement and the 1887 agreement; the opinion describes both. The Tribe's own account of the lake is not used here.

Who is doing the work

Native legal and land defense, nationally

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Connections

Links marked “suggested” were matched automatically by name or date and have not yet been reviewed by a person.

Doctrine applied 3

Policy era 1

Nations named 1

Sources

  1. supreme.justia.com/cases/federal/us/533/262/legal text copy
The record’s fields
Holding
The United States holds title in trust for the Tribe to the submerged lands under parts of Lake Coeur d'Alene and the St. Joe River; the tribe's historic dependence on the lake supported a purposeful reservation. Rehnquist dissented.
Kind
Court case
Confidence
High

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