Mattz v. Arnett

What happened

Mattz, a Yurok, or Klamath River, Indian, intervened in a forfeiture proceeding to get back five gill nets that a California game warden had confiscated. He said the nets were seized in "Indian country," where California's fishing statutes did not apply to him.

The Klamath River Reservation was established by Executive Order in 1855. In 1891, by Executive Order, it was made part of the Hoopa Valley Reservation. The next year, the Act of June 17, 1892 declared "all of the lands embraced in what was Klamath River Reservation" "subject to settlement, entry, and purchase" under the homestead laws, and provided that any Indian located there could take an allotment. The state trial court found that the reservation "for all practical purposes almost immediately lost its identity," and the California Court of Appeal affirmed, holding that opening the area to homestead entry had ended the reservation.

The Supreme Court unanimously disagreed, in an opinion by Justice Brennan. It held that the 1892 Act did not terminate the reservation, so the land was still Indian country under 18 U.S.C. section 1151. Allotment under the 1892 Act, it said, "is completely consistent with continued reservation status." The Act's mention of what "was" the Klamath River Reservation did not show a purpose to end it, but was a convenient way to identify land that had just been added to the Hoopa Valley Reservation.

In DeCoteau v. District County Court (1975), the Court distinguished Mattz when it held that an 1891 act had terminated the Lake Traverse Reservation.

Good to know. The opinion calls Mattz a Klamath River Indian; the syllabus calls him Yurok.

Summarized with AI assistance from 3 sources and checked against their words; not yet reviewed by historians or by the nations. Report an error