Facts of the Case
Respondent, a non-Indian, was operating a general store in Arizona on the Navajo Indian Reservation under a license required by federal statute. He brought an action in an Arizona Arizona state court against petitioners, a Navajo Indian and his wife who live on the Reservation, to collect for goods sold to them there on credit. Petitioners moved to dismiss on the ground that jurisdiction lay in the tribal court rather than in the state court. The state court refused to grant petitioners’ motion and ruled in favor of respondent. The Supreme Court of Arizona affirmed, holding that since no Act of Congress expressly forbade their doing so, Arizona courts were free to exercise jurisdiction over civil suits by non-Indians against Indians though the action arises on an Indian reservation. Petitioners sought review.
Did the state court have jurisdiction?
In a unanimous decision by Justice Hugo Black, the Court held that the Arizona state court improperly exercised jurisdiction, because states lack power to regulate Native American affairs on a reservation. The Court reasoned that the Navajo Courts of Indian Offenses exercised broad criminal and civil jurisdiction that covered suits by outsiders against Native American defendants. Federal law granted states the power to assume jurisdiction over reservation matters if the state legislature or the people affirmatively accepted the responsibility, and Arizona expressly disclaimed such jurisdiction. The Court concluded that the Navajo Treaty of 1868 controlled, and civil jurisdiction resided with the reservation’s courts.
- Citation: 358 US 217 (1959)
- Argued: Nov 20, 1958
- Decided Jan 12, 1959