Williams v. Lee

What happened

A man who was not an Indian ran a general store, the Ganado Trading Post, on the Navajo Indian Reservation in Arizona under a license required by federal statute. He sued a Navajo man and his wife, who lived on the reservation, in an Arizona state court. He wanted to collect for goods sold to them on credit at the store.

They moved to dismiss, saying jurisdiction lay in the tribal court, not the state court. The state court gave judgment for the trader, and the Arizona Supreme Court affirmed. It held that because no Act of Congress expressly forbade it, Arizona courts were free to hear civil suits by non-Indians against Indians even when the action arose on a reservation.

On January 12, 1959, the Supreme Court reversed. Justice Black noted that a treaty signed June 1, 1868 with the Navajos "set apart" a portion of their native country as their "permanent home." At that time the Navajos were an exiled people, forced by the United States to live crowded on a small piece of land on the Pecos River in eastern New Mexico.

The Court held that allowing state jurisdiction "would undermine the authority of the tribal courts over Reservation affairs and hence would infringe on the right of the Indians to govern themselves." It said that right was recognized by Congress in the Treaty of 1868 and had never been taken away. It was immaterial, the Court added, that the trader was not an Indian, since he was on the reservation and the transaction took place there.

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