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The original documents are located in Box 19, folder "Indians - Passamaquoddy Case" of the Philip Buchen Files at the Gerald R. Ford Presidential Library. Copyright Notice The copyright law of the United States (Title 17, United States Code) governs the making of photocopies or other reproductions of copyrighted material. Gerald R. Ford donated to the United States of America his copyrights in all of his unpublished writings in National Archives collections. Works prepared by U.S. Government employees as part of their official duties are in the public domain. The copyrights to materials written by other individuals or organizations are presumed to remain with them. If you think any of the information displayed in the PDF is subject to a valid copyright claim, please contact the Gerald R. Ford Presidential Library. Digitized from Box 19 of the Philip Buchen Files at the Gerald R. Ford Presidential Library THE WHITE HOUSE WASHINGTON Passamaquoddy Issue 1. Interior finish up work on its Litigation Report to Justice. 2. In this process, invite State and Indians' input. (State has asked for this so have Indians). 3. Interior send final Litigation Report to Justice. 4. Justice release this to the interested parties. 5. White House send letters to the parties inviting written input to a "settlement concept" option paper. 6. White House host one or more informal conferences of the parties to compare the inputs and clarify the issues and gather the pieces of such an option paper. 7. White House, together with Justice, Interior and Indians and in consultation with State, Congressional Delegation etc draw up option paper for President Carter. 8. Justice report the completion of this staff work to Judge Gignoux on his deadline of January 15, 1977, and then, and in the light of this, request a 30-day extension of the Judge's deadline so that PPresident Carter can make up his mind. GERALD FORD LIBRARY 9. Outcome of the option paper might be the draft of legislation which Carter could promptly send to Congress -- so that early Congressional action can minimize economic disruption in Maine. JOINT TRIBAL COUN. OF PASSAMAQUODDY TRIBE V. MORTON 649 Cite as 388 .Supp. 649 (1975) orated in the Other case in similar situation is nors against federal officials for a de- soever? of the Demsey & Associates Inc. V. SS Sea claratory judgment as to the applicabili- rate and pay- Star, 321 F.Supp. 663 (S.D.N.Y.1970), ty of the Indian Nonintercourse Act to therein.' where while each bill of lading was sub- the Tribe. The State of Maine was per- language of titled, To be used with Charter-Par- mitted to intervene as a party defend- by the spe- ties" and contained the following addi- ant. The District Court, Gignoux, J., aves no fair tional language with regard to charter held that although the Tribe was never of the par- parties, "*** freight at the rate of federally recognized" by a treaty be- is SO plain (say per ) as per Charter-Party, tween the United States and the Tribe, arbitration in dated the Nonintercourse Act was applicable brought over "All the terms, conditions, liberties, to the Tribe and established a trust rela- nnecessary to and exceptions of the Charter-Party are tionship between the United States and this instance herewith incorporated". the Tribe. The Court held that this does not show Judgment for plaintiffs. party are, what, if any, charter party was intended rporated into to be incorporated. are a part of and are bind- In view of the fact that there is no 1. Statutes 181(1), 189 for plain or express incorporation of the In construing statute duty of court dam- that contract charter party in the bill of lading and is to give effect to intent of Congress, the dispute also based on the decisions of Son Ship- and in SQ doing the first reference is to and the ping Co. Inc. V. De Fosse & Tanghe, su- the literal meaning of words employed. added). pra; and Demsey and Associates Inc. V. 2. Statutes -212.6 SS Sea Star, supra, defendant's motion Unless contrary appears, it is pre- & Molasses to stay proceedings pending arbitration sumed that statutory words were used in holson, 126 F. is hereby denied. their ordinary sense. it was held It is 80 ordered. referred to a 3. Statutes 181(1), 184 blank the Primary consideration in construing he date of the statute is the mischief to be corrected bar) was in- KEY NUMBER SYSTEM and the end to be attained by enactment terms of the of the legislation; where possible terms he bill of lad- of statute should be construed to give effect to congressional intent. ading read as 4. Statutes ©217.2, 223.1 JOINT TRIBAL COUNCIL OF the PAS- SAMAQUODDY TRIBE et al., Extrinsic aids such as legislative under and Plaintiffs, history of statute and the accepted in- the charter terpretation of similar language in relat- V. between ed legislation are helpful in interpreting Rogers C. B. MORTON, Secretary, De- as charterer, ambiguous statutory language. partment of the Interior, et al., soever of the Defendants, 5. Statutes 219(1) and pay- and Administrative interpretations by therein ap- State of Maine, Intervenor. agency entrusted with enforcement of rights of the Civ. No. 1960. statute are persuasive but the power to is shipment." United States District Court, issue regulations is not the power to form bill of D. Maine, N.D. change the law and it is for the courts those which Jan. 20, 1975. to determine whether or not administra- the incorpo- tive interpretations are consistent with As Amended Feb. 11, 1975. intent of Congress and words of statute. or no incorpo- 6. Indians -6 charter party Action was brought by the Joint Indian Nonintercourse Act, whose Tribal Council of the Passamaquoddy literal language used in the ordinary AUTHORI Indian Tribe and the Tribe's two gover- sense clearly encompasses all tribes of 388 650 388 FEDERAL SUPPLEMENT Indians, is applicable to the Passama- United States to protect land owned by quoddies, although Federal Government Tribe. 25 U.S.C.A. § 177. had never entered into a treaty with the 12. Indians 15(1) Tribe, Congress had never enacted legis- By virtue of duty imposed by the lation which specifically mentioned the Indian Nonintercourse Act, United Tribe and the Commonwealth of Massa- States has an obligation to do whatever chusetts and the State of Maine had as- is necessary to protect Indian land when sumed almost exclusive responsibility it becomes aware that Indian rights for protection and welfare of the Passa- have been violated, even though United maquoddies. 25 U.S.C.A. § 177; 28 U. States did not participate in the uncon- S.C.A. § 1331. scionable transaction. 25 U.S.C.A. § 7. Statutes 189 177. Departure from plain meaning of 13. Indians =3 statutory language is only justified Termination of Federal Govern- where application of literal language ment's responsibility for Indian tribe re- would be at variance with legislative in- quires plain and unambiguous action ev- tent as revealed by statute as a whole idencing a clear and unequivocal inten- and its legislative history. tion of Congress to terminate its rela- 8. Indians 15(2) tionship with the tribe. Purpose of Indian Nonintercourse 14. Indians =3 Act forbidding conveyance of Indian Where Congress never expressly land without consent of the United terminated its relationship with the Pas- States is to protect land of Indian tribes samaquoddy Tribe, failure of Federal in order to, prevent fraud and unfair- Government to object to Maine's under- ness. 25 U.S.C.A. § 177. taking certain obligations for protection 9. Indians 15(2) of Tribe did not evidence such a clear Plain meaning interpretation of congressional intent as would support phrase "any tribe of Indi- a finding of a termination of Federal ans" as used in Indian Nonintercourse Government's obligation toward the Pas- Act, forbidding conveyance of Indian samaquoddies. 25 U.S.C.A. § 177. lands without consent of United Statès, is the only construction of Act which 15. Constitutional Law -68(1) comports with basic policy of United Political question doctrine did not States as reflected in Act to protect In- bar court from granting declaratory dian right of occupancy of their aborigi- judgment that the Indian Noninter- nal lands. 25 U.S.C.A. § 177. course Act did apply to the Passama- quoddy Tribe since only issue before 10. Indians -6 court was whether Congress once having Language used in statutes confer- exercised its power to pass protective ring benefits or protection on Indians legislation on behalf of Indians meant to must be construed in a nontechnical include Tribe and this presented a ques- sense as the Indians themselves would tion of legislative intent for resolution have understood it, and all ambiguities by court rather than nonjusticiable in such statutes are to be resolved in fa- political question. 25 U.S.C.A. § 177; vor of the Indiana 28 U.S.C.A. § 1331. IL Indians 15(2) 16. Administrative Law and Procedure Indian Nonintercourse Act, forbid- 704 ding conveyance of Indian land without Where Attorney General of United consent of United States, was applicable States in his refusal to institute suit on to the Passamaquoddy Tribe, although behalf of Indian tribe relied exclusively never "federally recognized," and im- on _recommendation of Secretary of the posed a trust er fiduciary obligation on Interior and the actions of the Attorney JOINT TRIBAL COUN. OF PASSAMAQUODDY TRIBE V. MORTON 651 Cite as 388 Supp. 649 (1975) land owned by General and the Secretary were but two Ross, Washington, D. C., Robert S. Pel- stages of single administrative process, cyger, and David H. Getches, Boulder, their action was a final agency action Colo., for plaintiffs. imposed by the reviewable under the Administrative Peter Mills, U.S. Atty., Portland, Me., Act, United Procedure Act. 5 U.S.C.A. §§ 701 et Floyd L. France, Chf. Litigation Section to do whatever seq., 704; 25 U.S.C.A. § 177; 28 U.S. and Anthony S. Borwick, Asst. Atty. ndian land when C.A. 1331, 2201. Gen., Civil Div., Dept. of Justice, Land Indian rights & Natural Resources Div., Washington, though United 17. Declaratory Judgment -304 Secretary of the Interior was prop- D.C., for defendants. te in the uncon- 25 U.S.C.A. § er party to suit by Indian tribe for dec- laration that the Indian Nonintercourse OPINION AND ORDER OF THE Act was applicable to it and established COURT a trust relationship between United 'ederal Govern- GIGNOUX, District Judge. States and tribe, since the Department Indian tribe re- of the Interior was a federal agency pri- Plaintiffs in this action are the Joint guous action ev- marily responsible for protecting Indian Tribal Council of the Passamaquoddy equivocal inten- land and administering government poli- Indian Tribe and the Tribe's two gover- minate its rela- cy pursuant to statutes. 25 U.S.C.A. § nors, who are suing in their individual 177; 28 U.S.C.A. § 1331. and official capacities and as representa- tives of all members of the Tribe. De- 18. Declaratory Judgment -203 fendants are the Secretary of the Interi- expressly Doctrine of action committed to or, the Attorney General of the United with the Pas- agency discretion by law did not pre- States, and the United States Attorney lure of Federal clude Indian tribe from bringing suit for the District of Maine. The State of Maine's under- for declaratory judgment that the Indi- Maine has been permitted to intervene for protection an Nonintercourse Act applied to it and as a party defendant. Plaintiffs seek a such clear established a special trust relationship declaratory judgment that the Indian would support between tribe and United States after Nonintercourse Act, 1 Stat. 137 (1790), of Federal Attorney General declined to bring suit now 25 U.S.C. § 177, forbidding the con- toward the Pas- on behalf of tribe, since suit did not veyance of Indian land without the con- 177. seek to require Attorney General to sent of the United States, is applicable (1) bring suit on tribe's behalf and the doc- to the Passamaquoddy Tribe and estab- loctrine did not trine of prosecutorial discretion could lishes a trust relationship between the declaratory not shield legal error resulting from the United States and the Tribe: This Noninter- erroneous legal conclusion of official Court has jurisdiction under 28 U.S.C. § the Passama- that the Indian Nonintercourse Act did 1331, Oneida Indian Nation V. County of lytissue before not apply to tribe. 5 U.S.C.A. § Oneida, 414 U.S. 661, 94 S.Ct. 772, 39 once having 701 (a) (2) 25 U.S.C.A. § 177; 28 U.S. L.Ed.2d 73 (1974), and declaratory re- pass protective C.A. §§ 516, 519. lief is sought pursuant to 28 U.S.C. § ndians meant to 2201. Plaintiffs also invoke applicable 19. Declaratory Judgment -91 resented a ques- provisions of the Administrative Proce- Indian tribe was not barred from for resolution dure Act, 5 U.S.C. § 701 et seq. The declaratory relief with respect to the ap- nonjusticiable case has been submitted upon a stipulat- plicability of the Indian Nonintercourse J.S.C.A. § 177; ed record, briefs and oral argument. Act to it merely because court might not be able to fashion coercive relief to com- The Historical Background Procedure pel Attorney General to bring suit on behalf of tribe. 25 U.S.C.A. § 177. The Joint Tribal Council of the Passa- maquoddy Tribe is the official govern- of United ing body of the Passamaquoddy Tribe, a institute suit on tribe of Indians residing on two reserva- exclusively Thomas N. Tureen, David C. Crosby, tions in the State of Maine. It is stipu- ecretary of the of the Attorney Barry A. Margolin, Calais, Me., Rob- lated that since at least 1776 the present ert E. Mittel, Portland, Me., Stuart P. members of the Tribe and their ances- 652 388 FEDERAL SUPPLEMENT tors have constituted and continue to tercourse Act, the Commonwealth of constitute a tribe of Indians in the ra- Massachusetts, Maine's predecessor in cial and cultural sense. interest², negotiated a treaty with the Plaintiffs allege that until 1794 the Passamaquoddies, by which the Tribe Passamaquoddy Tribe occupied as its ceded to Massachusetts practically all of aboriginal territory all of what is now its aboriginal territory. It is further al- Washington County together with other leged that out of the 23,000 acres which land in the State of Maine. During the the 1794 treaty reserved to the Tribe, Maine and Massachusetts have sold, Revolutionary War, the Tribe fought with the American colonies against leased for 999 years, given easements Great Britain. In 1790, in recognition on, or permitted flooding of approxi- of the primary responsibility of the mately 6,000 acres. The complaint as- serts that the United States has not con- newly-formed Federal Government to sented to these transactions and there- the Indians in the United States, Oneida Indian Nation V. County of Oneida, fore that they violated the express terms of the Nonintercourse Act. supra at 667, 94 S.Ct. 772; United States V. Sante Fe Pacific R. Co., 314 Since the United States was organized U.S. 339, 345, 347-348, 62 S.Ct. 248, 86 and the Constitution adopted in 1789, L.Ed. 260 (1941), the First Congress the Federal Government has never en- adopted the Indian Nonintercourse Act, tered into a treaty with the Passama- which as presently codified, 25 U.S.C. § quoddy Tribe, and the Congress has nev- 177, provides in pertinent part: er enacted legislation which specifically mentions the Passamaquoddies. Fur- No purchase, grant, lease, or other thermore, since 1789, the contacts be- conveyance of lands, or of any title or tween the Federal Government and the claim thereto, from any Indian nation Tribe have been sporadic and infre- or tribe of Indians, shall be of any va- quent. In contrast, the State of Maine lidity in law or equity, unless the has enacted comprehensive legislation same be made by treaty or convention which has had a pervasive effect upon entered into pursuant to the Constitu- all aspects of Passamaquoddy tribal life. tion.¹ The stipulated record clearly shows that Plaintiffs allege that in 1794, four the Commonwealth of Massachusetts and years after passage of the 1790 Nonin- the State of Maine, rather than the Fed- 4. The first Nonintercourse Act passed in Stat. 729, 730; and in Rev.Stat. § 2116, 1790, 1 Stat. 137, 138, provided that "no now 25 U.S.C. § 177. sale of lands made by any Indians, or any 2. Maine was formerly a District of Massa nation or tribe of Indians within the United chusetts. In 1819 Massachusetts passed leg- States, shall be valid to any person or per islation, commonly known as the Articles of sons, or to any state unless the Separation, which permitted, subject to the same shall be made and duly executed consent of Congress, the separation of the some public treaty, held under the authority District of Maine from Massachusetts, and of the United States.' By the second Non- the establishment of Maine as an indepen intercourse Act passed in 1793, this lan- dent state. Act of June 19, 1819, Mass. guage was amended to read as follows: "No Laws, ch. 61, p. 248. The Articles of Sepa- purchase or grant of lands, or of any title ration provided that Maine would "assume or claim thereto, from any Indians or nation and perform all the duties and obligations of or tribe of Indians, within the bounds of the this Commonwealth towards the Indians United States, shall be of any validity in law within said District of Maine, whether the or equity, unless the same be made by a same arise from treaties or otherwise; treaty or convention entered into pursuant Shortly thereafter, Congress ap- to the Constitution." 1 Stat. 329, 330. proved of Maine's admission to the Union. This version was carried forward, without Act of March 3, 1820, ch. 19, 3 Stat. 544. major change, in the 1796 Act, 1 Stat. 469, The Articles of Separation were incorporat- 472; the 1799 Act, 1 Stat. 743, 746; the ed into the Maine Constitution as Article X, 1802 Act, 2 Stat. 139, 143; the 1834 Act, 4 Section 5.3 Const. art. 10, § 5. JOINT TRIBAL COUN. OF PASSAMAQUODDY TRIBE V. MORTON 653 Cite as 388 F.Supp. 649 (1975) nonwealth of eral Government, have assumed almost the Court directed defendants, in the redecessor in exclusive responsibility for the protec- event their decision was in the negative, with the tion and welfare of the Passamaquod- to state their reasons for so deciding and the Tribe dies.³ to show cause on June 23, 1972 why they actically all of should not be ordered to bring suit. On is further al- The Present Action June 20, 1972 the Acting Solicitor of the acres which Department of the Interior advised the to the Tribe, On February 22, 1972 representatives Assistant Attorney General, Land and have sold, of the Passamaquoddy Tribe wrote to Natural Resources Division, Department easements the Commissioner of the Bureau of Indi- of Justice, by letter, that no request for of approxi- an Affairs, Department of the Interior, litigation would be made. The reasons, complaint as- and requested that the United States as stated in the letter, were as follows: has not con- Government, on behalf of the Tribe, in- stitute a suit against the State of Maine, As you are ware, no treaty exists and there- between the United States and the express terms as a means of redressing the wrongs which arose out of the alleged uncon- Tribe and, except for isolated and scionable land transactions in violation inexplicable instances in the past, this was organized of the Nonintercourse Act. The letter Department, in its trust capacity, has in 1789, urged that the requested action be filed had no dealings with the Tribe. On has never en- by July 18, 1972, the date as of which the contrary, it is the States of Mas- the Passama- sachusetts and Maine which have act- such an action would be barred by 28 agress has nev- U.S.C. $ 2415(b), a special statute of ed as trustees for the tribal property specifically limitations for actions seeking damages for almost 200 years. This relation- uoddies. Fur- resulting from trespass upon restricted ship between the Tribe and the States contacts be- Indian lands. On March 24, 1972 the has apparently never been questioned nment and the Commissioner recommended to the Solic- by the Tribe until recently. and infre- itor of the Department of the Interior State of Maine that the litigation be instituted and ad- In view of the Court's Order of legislation vised the Solicitor that 28 U.S.C. § June 16, 1972, requesting it be ad- effect upon 2415(b) might bar a suit after July 18, vised of the Secretary's decision on tribal life. 1972. Defendants, however, despite re- the Tribe's request by June 22, 1972, shows that peated urgings by representatives of the this Department has again reviewed its ssachusetts and Tribe, failed to take any action upon position and has again determined than the Fed- their request. that no request for litigation should Stat. $ 2116, On June 2, 1972 plaintiffs filed the be made. present action seeking a declaratory The Department does not reach its District of Massa- judgment that the Passamaquoddy Tribe decision lightly. On the one hand, we nusetts, passed leg- is entitled to the protection of the Non- are aware that the tribe may thus be the Articles of subject to the intercourse Act and requesting a prelim- foreclosed from pursuing its claims separation of the inary injunction ordering the defendants against the State in the federal fassachusetts, and to file a protective action on their behalf courts. However, as there is no trust as an indepen- against the State of Maine before-July relationship between the United 19, 1819, Mass. 18, 1972. Following a hearing on June States and this tribe, we are led ines- Articles of Sepa- 16, 1972 the Court ordered defendants to capably to conclude that the Tribe's would "assume and obligations of decide by June 22, 1972 whether they proper legal remedy should be sought the Indians would voluntarily file the protective ac- elsewhere. (emphasis sup- whether the tion sought by plaintiffs. In addition, plied). or otherwise; Congress ap- 3. The contacts between the Federal Govern- 4. Congress has since extended the time for to the Union. 19, 3 Stat. 544. ment and the Passamaquoddies, and between filing such an action to July 18, 1977. Act Massachusetts and Maine and the Passama- of October 13, 1972, P.L. 92-485, 86 Stat. were incorporat- Article X, quoddies, since 1776, as disclosed by the doc- 803. as 5. uments stipulated into the record in this case, are set forth in detail in the Appendix to this Opinion. 654 388 FEDERAL SUPPLEMENT On June 22, 1972, by means of a written action as a party defendant. On July Notice filed with the Court, enclosing a 15, 1974, following the completion of dis- copy of the June 20, 1972 letter from covery, plaintiffs filed a second amended the Department of the Interior to the and supplemental complaint Department of Justice, defendants noti- The action is presently before the fied the Court that they would not vol- Court on the basis of plaintiffs' second untarily file the requested action. The amended and supplemental complaint, Notice stated: defendants' and intervenor's answers You are hereby further notified thereto, a stipulated record, briefs and that consistent with the decision of oral argument. the Interior Department, the Assist- ant Attorney General in charge of the The Issues Presented by the Land and Natural Resources Division, Present Action Department of Justice, acting under and by delegation from the Attorney In their second amended and supple- General, has decided not to institute mental. complaint, plaintiffs have an action against the State of Maine dropped their original request for in- as requested by plaintiffs' counsel. junctive relief and seek only a declarato- (emphasis supplied) ry judgment. Their basic position is that the Nonintercourse Act applies to At the conclusion of the show cause all Indian tribes in the United States, hearing held on June 23, 1972 the Court including the Passamaquoddies, and that ordered defendants to file the requested the Act establishes a trust relationship protective action against the State of between the United States and the Indi- Maine prior to July 1, 1972.5 On June an tribes to which it applies, including 29, 1972 defendants complied with the the Passamaquoddies. Therefore, they Court's order by filing an action, United say, defendants may not deny plaintiffs' States y. Maine, Civil No. 1966 N.D., in request for litigation on the sole ground this Court." that there is no trust relationship be- On February 1, 1973 plaintiffs filed tween the United States and the Tribe.⁷ an amended and supplemental complaint In opposition, defendants and intervenor in the present action, abandoning their contend that only those Indian tribes original request for injunctive relief and which have been "recognized" by the seeking only a declaratory judgment Federal Government by treaty, statute that the Passamaquoddies are entitled to or a consistent course of conduct are en- the protection of the Nonintercourse titled to the protection of the Noninter- Act. On June 17, 1973 the State of course Act and, since the Passamaquod- Maine was permitted to intervene in the dies have not been "federally recog- 5. Defendants' appeal from the June 23, 1972 7. In their second amended and supplemental order was dismissed by the United States complaint, plaintiffs also seek a declaratory Court of Appeals for the First Circuit on judgment that the Tribe is entitled to the motions filed by plaintiffs and defendants, protection of U. S. Const. art. I, $ 8 ("The after the Solicitor General had refused de- Congress shall have power [t]o fendants permissión to proceed. regulate Commerce with the Indi- an Tribes"), art. 10 ("[n]o State shall 6. On July 26, 1972, pursuant to stipulation, enter into any Treaty and art. the Court ordered that the protective action II, q.2 ("[t]he President shall filed against the State of Maine by the Unit- have power, by and with the Advice and ed States on behalf of the Passamaquoddies Consent of the Senate, to make Treaties and a similar action filed by the United "). Plaintiffs have not pressed their States on behalf of the Penobscot Indian initial request for this relief, and the appli- Nation, United States V. Maine, Civil No. cability to the Passamaquoddies of these 1969 N.D., be held in abeyance on the Constitutional provisions is not presently in Court's docket and that no action need be issue. taken by the parties in either suit pending the outcome of the present action. JOINT TRIBAL COUN. OF PASSAMAQUODDY TRIBE V. MORTON 655 Cite as 388 F.Supp. 649 (1975) On July nized," the Act is not applicable to them. end to be attained" by the enactment of dis- Defendants and intervenor also deny of the legislation; and, where possible, amended that the Nonintercourse Act creates any its terms should be construed to give trust relationship between the United effect to the Congressional intent. fore the States and the Indian tribes to which it Extrinsic aids such as the legislative second applies. history of the Act, and the accepted in- omplaint, In addition to denying that the Passa- terpretation of similar language in re- answers maquoddies are protected by the Nonin- lated legislation, are helpful in inter- and tercourse Act, defendants and intervenor preting ambiguous statutory language. raise. several affirmative defenses. Finally, administrative interpretations First, they say that defendants' refusal by the agency entrusted with the en- to institute suit on behalf of the Passa- forcement of the statute are persua- maquoddies is not subject to judicial re- sive. However, the power to issue regu- supple- view under the provisions of the Admin- lations is not the power to change the have istrative Procedure Act, 5 U.S.C. § 701 law, and it is for the courts, to which for in- et seq., both because it is not "final the task of statutory construction is eclarato- agency action," 5 U.S.C. § 704, and be- ultimately entrusted, to determine cause it constitutes "agency action whether or not administrative inter- is pplies to committed to agency discretion pretations are consistent with the in- States, by law," 5 U.S.C. § 701 (a) (2). Next, tent of Congress and the words of the and that intervenor asserts that the Court lacks Act. 318 F.2d at 142-143. (citations tionship jurisdiction of the action because it omitted). the Indi- presents a nonjusticiable "political ques- Applying these rules of construction, the ncluding tion." Finally, intervenor contends that conclusion is inescapable that, as a mat- they the case is not one in which declaratory ter of simple statutory interpretation, aintiffs' relief is proper. Plaintiffs respond that the Nonintercourse Act applies to the ground these affirmative defenses are without Passamaquoddies. The literal meaning be- merit. of the words employed in the statute, Tribe.⁷ The Court will deal separately with used in their ordinary sense, clearly and tervenor each of the issues thus presented. unambiguously encompasses all tribes of tribes Indians, including the Passamaquoddies; by the The Applicability of the Nonintercourse the plain language of the statute is con- statute Act to the Passamaquoddies sistent with the Congressional intent; are en- [1-6] The rules of statutory inter- and there is no legislative history or ad- oninter- pretation by which this Court must be ministrative interpretation which con- maquod- guided in determining the applicability flicts with the words of the Act. recog- of the Nonintercourse Act to the Passa- [7] The provisions of the Noninter- maquoddies are summarized in United plemental course Act prohibiting dealings in Indi- States V. New England Coal and Coke eclaratory an land without the consent of the Unit- to the Co., 318 F.2d 138 (1st Cir. 1963), fol- ed States have remained essentially un- 8 ("The lows: changed since passage of the first Act [t]o "In matters of statutory construction in 1790.8 The statute in effect in 1794, the Indi- shall the duty of this court is to give effect when Massachusetts negotiated its and art. to the intent of Congress, and in treaty with the Passamaquoddies, ap- shall doing so our first reference is of plied to land transactions with "any In- dvice and course to the literal meaning of words dians or nation or tribe of Indians," Treaties their employed." Unless the contrary ap- within the United States. Act of March the appli- pears, it is presumed that statutory 1, 1793, 1 Stat. 329, 330. Subsequent of these words were used in their ordinary versions of the statute, including the esently in sense. A primary consideration is present codification, have applied to land 'the mischief to be corrected and the transactions with "any Indian nation or 8. See n. 1, supra. 656 388 FEDERAL SUPPLEMENT tribe of Indians." The words employed to the applicability of the Act to the in the statute are clear and unambigu- Passamaquoddies or any similarly situ- ous; the prohibition against dealings in ated Indian tribe. Every court, how- Indian land without the consent of the ever, which has considered the purposes United States is applicable to "any of the Act has agreed that the intent of tribe of Indians." In the Congress was to protect the lands of the present case, it is stipulated that the Indian tribes in order to prevent fraud Passamaquoddies are a "tribe of Indi- and unfairness. As the Supreme Court ans." It may be conceded that the Tribe noted in Federal Power Commission V. has not been "federally recognized," but Tuscarora Indian Nation, 362 U.S. 99, there is no suggestion in the statute 119, 80 S.Ct. 543, 555, 4 L.Ed.2d 584 that, as defendants and intervenor con- (1960) tend, the Act is not applicable to a partic- The obvious purpose of that [the ular Indian tribe unless that tribe has Nonintercourse] statute is to prevent been recognized by the Federal Govern- the unfair, improvident or improper ment by a formal treaty, mention of the disposition by Indians of lands owned tribe in a statute, or a consistent course or possessed by them to other parties, of administrative conduct. A departure except the United States, without the from the plain meaning of statutory lan- consent of Congress, and to enable the guage is only justified where the appli- Government, acting as parens patriae cation of literal languge would be at for the Indians, to vacate any disposi- variance with legislative intent as re- tion of their lands made without its vealed by the statute as a whole and its consent. legislative history, Marks V. United The decided cases are replete with simi- States, 161 U.S. 297, 301, 16 S.Ct. 476, lar statements of the Act's purpose. E. 40 L.Ed. 706 (1896) Otoe and Missour- G., United States V. Candelaria, 271 U.S. ia Tribe of Indians V. United States, 131 432, 441-442, 46 S.Ct. 561, 562, 70 L.Ed. F.Supp. 265, 276, 131 Ct.Cl. 593, cert. de- 1023 (1926) (the intent of Congress was nied, 350 U.S. 848, 76 S.Ct. 82, 100 L. "to prevent the Government's Indian Ed. 755 (1955). wards from improvidently disposing of [8] Neither defendants nor interve- their lands and becoming homeless pub- nor have suggested any reason why giv- lic charges," and thereby to protect "a ing the term "any tribe of In- simple, uninformed people, ill-prepared dians" its literal meaning, thereby en- to cope with the intelligence and greed compassing the Passamaquoddies, would of other races"); Tuscarora Nation of lead to a result at variance with the stat- Indians V. Power Authority, 257 F.2d utory objectives of the Nonintercourse 885, 888 (2d Cir. 1958), vacated as moot Act. To the contrary, it is eminently sub nom. McMorran V. Tuscarora Nation clear that the literal interpretation of of Indians, 362 U.S. 608, 80 S.Ct. 960, 4 the statute is required to give effect to L.Ed.2d 1009 (1960) (the statute was the Congressional intent. The Court is enacted "to prevent Indians from being aware of no legislative history of the victimized by artful scoundrels inclined Nonintercourse Act, which might reveal to make a sharp bargain"); Alonzo V. whether the First Congress had in mind United States, 249 F.2d 189, 196 (10th the Passamaquoddies when it enacted Cir. 1957), cert. denied, 355 U.S. 940, 78 the 1790 Act. Nor have defendants S.Ct. 429, 2 L.Ed.2d 421 (1958) (the been able to call to the Court's attention purpose of such legislation is to protect any administrative interpretation prior the Indians "against the loss of-their to the filing of the instant litigation as lands by improvident disposition 9. Clearly, the administrative determination than challenged is not authoritativé Davies made in response to this Court's order of June 16, 1972, cannot so qualify. An admin- Warehouse Co. V. Bowles, 321 U.S. to 144, 156, 64 S.Ct. 474, 88 L.Ed. 635 (1944). LIBRARY istrative ruling which is no sooner made JOINT TRIBAL COUN. OF PASSAMAQUODDY TRIBE V. MORTON 657 Cite as 388 F.Supp. 649 (1975) through overreaching by members of S.Ct. 772, decided last Term, the Su- the Act to the other races"). Seneca Nation of Indians preme Court: reaffirmed these funda- y similarly situ- V. United States, 173 Ct.Cl., 917, 923 mental propositions stated in Santa Fe. very court, how- (1965) ("From the beginning, this legis- In Oneida, the Supreme Court also again red the purposes lation has been interpreted as giving the summarized the policy of the United hat the intent of Federal Government a supervisory role States to protect the rights of Indian t the lands of the over conveyances by Indians to others, tribes to their aboriginal lands: to prevent fraud in order to forestall fraud and unfair- e Supreme Court It very early became accepted doc- ness."). er Commission V. trine in this Court that although fee ion, 362 U.S. 99, title to the lands occupied by Indians [9] A plain meaning interpretation 4 L.Ed.2d 584 when the colonists arrived became of the phrase "any tribe of vested in the sovereign-first the dis- Indians" is also the only construction of covering European nation and later ose of that [the the Nonintercourse Act which comports the original States and the United ;ute is to prevent with the basic policy of the United States-a right of occupancy in the dent or improper States, as reflected in the Act, to protect Indian tribes was nevertheless recog- is of lands owned the Indian right of occupancy of their nized. That right, sometimes called 2 to other parties, aboriginal lands Thus, in United Indian title and good against all but lates, without the States V. Santa Fe Pacific R: Co., supra, the sovereign, could be terminated and to enable the 314 U.S. at 348, 62 S.Ct. at 252, the Su- only by sovereign act. Once the Unit- as parens patriae preme Court cited the Act as embodying ed States was organized and the Con- acate any disposi- the unquestioned general stitution adopted, these tribal rights made without its policy of the Federal Government to to Indian lands became the exclusive recognize such right of occupancy. province of the federal law. Indian replete with simi As stated by Chief Justice Marshall in title, recognized to be only a right of Act's purpose. E. Worcester V. Georgia, supra, 6 Pet. occupancy, was extinguishable only by andelaria, 271 U.S. [515,] at page 557, 8 L.Ed. 483, the the United States. The Federal Gov- 561, 562, 70 L.Ed. Indian trade and intercourse acts ernment took early steps to deal with it of Congress was "manifestly consider the several Indi- the Indians through treaty, the princi- ernment's Indian an nations as distinct political com- pal purpose often being to recognize ently disposing of munities, having territorial bounda- and guarantee the rights of Indians to ing homeless pub ries, within which their authority is specified areas of land. This the eby to protect "a exclusive, and having a right to all the United States did with respect to the eople, prepared lands within those boundaries, which various New York Indian tribes, in- ligence and greed is not only acknowledged, but guaran- cluding the Oneidas. The United scarora Nation of tied by the United States. States also asserted the primacy of thority, 257 F.2d Santa Fe also established that "recogni- federal law in the first Noninter- ), vacated as moot tion" is not a prerequisite to Noninter- course Act passed in 1790, 1 Stat. 137, Tuscarora Nation course Act protection: 138, which provided that "no sale of 08, 80 S.Ct. 960, Nor is it true, as respondent urges, lands made by any Indians (the statute was that a tribal claim to any particular within the United States, shall be val- ndians from being lands must be based upon a treaty, id to any person or to any scoundrels inclined statute, or other formal government state unless the same shall gain"); Alonzo V. action. As stated in the Cramer case be made and duly executed at some 2d 189, 196 (10th [Cramer V. United States, 261 U.S. public treaty, held under the authority d, 355 U.S. 940, 78 219, 229, 43 S.Ct. 342, 67 L.Ed. 622 of the United States." This has re- 421 (1958) (the (1923)], "The fact that such right of mained the policy of the United States lation is to protect occupancy finds no recognition in any to this day. See 25 U.S.C. § 177. 414 the loss of their statute or other formal governmental U.S. at 667-668, 94 S.Ct. at 777. nt disposition or action is not conclusive." 314 U.S. at (footnote omitted). authoritative. Davies 347, 62 S.Ct. at 252. It is thus clear that the policy embod- les, 321 U.S. 144, 156, In Oneida Indian Nation V. County of ied in the Nonintercourse Act is to pro- 35 (1944). Oneida, supra, 414 U.S. at 667-668, 94 tect Indian tribes against loss of their 388 F.Supp.-42 658 388 FEDERAL SUPPLEMENT aboriginal lands by improvident disposi- rights, including that of voting and tion to members of other races. The holding office, and their absorption Passamaquoddies, an Indian tribe, fall into the general mass of the popula- within the plain meaning of the statuto- tion (except that they held their lands ry language, and there is no reason why in common), all forbid the idea that they should be excluded from the protec- they should be classed with the Indian tion which the Act affords. tribes for whom the intercourse acts Defendants and intervenor rely on a were made, or that in the intent of trilogy of Supreme Court cases, all in- the act of 1851 its provisions were ap- volving the Pueblo Indians in New Mex- plicable to them. The tribes for ico, for the contention that, despite the whom the act of 1834 was made were all-inclusive language of the Noninter- those semi-independent tribes whom course Act, the Act applies only to Indi- our government has always recognized an tribes which have been "federally as exempt from our laws, whether recognized" by treaty, statute or a con- within or without the limits of an sistent course of conduct: United States organized State or Territory, and, in V. Joseph, 94 U.S. 614, 24 L.Ed. 295 regard to their domestic government, (1876) United States V. Sandoval, 231 left to their own rules and traditions; U.S. 28, 34 S.Ct. 1, 58 L.Ed. 107 (1913); in whom we have recognized the ca- United States Candelaria, supra. pacity to make treaties, and with Close analysis of these decisions, how- whom the governments, state and na- ever, leaves little doubt that the Act tional, deal, with a few exceptions only, means what it says and that the protec- in their national or tribal character, tion of the Act is not limited to "recog- and not as individuals. 94 U.S. at 617. nized" tribes. It is unclear whether the Court held that Congress had extended the 1834 Non- the Pueblos were a tribe outside the intercourse Act to the New Mexico and scope of the Act, or simply not a tribe. Utah territories in 1851. Act of Feb. In either event, it is clear that, by the 27, 1851, ch. 14, $ 7, 9 Stat. 587. The standards applied in Joseph, even if the applicability of the Act to the Indians of case is still good law,¹⁰ the Passama- the Pueblo of Taos in New Mexico was quoddies in 1794 were "uncivilized" In- at issue in the Joseph case. The Court dians to whom the Act would apply. there held that the Act applied only to More importantly, the Court's opinion "uncivilized" Indians, and therefore did plainly does not contain any suggestion not protect Indians such as the Pueblos that "federal recognition" is a precondi- and the Senecas or Oneidas of New tion to the Act's applicability. York, who, unlike the "nomadic" Apach- Defendants' reliance on the Sandoval es, Comanches and Navajoes, had at- case is equally misplaced. That case in- tained a high degree of civilization: volved not the Nonintercourse Act, but The pueblo Indians, if, indeed, they the Act of January 30, 1897 ch. 109, 29 can be called Indians, had nothing in Stat. 506, a criminal statute prohibiting common with this class. The degree the introduction of intoxicating liquor of civilization which they had attained into "Indian country." Congress had centuries before, their willing submis- expressly made this statute applicable to sion to all the laws of the Mexican lands owned by the Pueblo Indians as a government, the full recognition by condition to the admission of New Mexi- that government of all their civil CO to statehood. Act of June 20, 1910, 10. As plaintiffs point out, the Court's state- respect to all three tribes. United States V. ment in Joseph that the Pueblos, the Sene- Candelaria, supra; Oneida Indian Nation V. cas and the Oneidas would be outside the County of Oneida, supra; Seneca Nation of scope of the Act because of their high de- Indians V. Urited States, supra. gree of civilization has been rejected with JOINT TRIBAL COUN, OF PASSAMAQUODDY TRIBE V. MORTON 659 Cite as 388 .Supp. 649 (1975) ch. 310, § 2, 36 Stat. 557. A criminal course Act, as extended to the New Mex- of voting and absorption prosecution brought pursuant to the ico territory in 1851. Candelaria was 1897 statute was dismissed by the Dis- an action brought by the United States of the popula- their lands trict Court on the ground that Congress to quiet title to land of the Pueblo of lacked authority to regulate the sale of Laguna occupied by José Candelaria, a the idea that liquor in the State of New Mexico. The non-Indian. The suit was brought on the Indian issue presented to the Supreme Court the theory that the Pueblos were wards tercourse acts the of was not one of statutory construction, as of the United States, which therefore intent Congress had made it clear in the 1910 had the authority and was under a duty were ap- for Act that the 1897 statute applied to the to protect them in the ownership of tribes Pueblo Indians. The only issue before their lands. 271 U.S. at 437, 46 S.Ct. made were the Court was whether "the status of 561. The issue presented to the Su- tribes whom the Pueblo Indians and their lands is preme Court was whether the guardian- recognized laws, whether such that Congress competently can pro- ward relationship between the United hibit the introduction of intoxicating li- States and the Pueblos was such that limits of an and, in quor into those lands notwithstanding the United States, as guardian of the the admission of New Mexico into state- Pueblos, was barred from bringing suit government, and traditions; hood," 231 U.S. at 38, 34 S.Ct. at 3, or by a judgment involving title to the whether the Pueblos instead were "be- same land entered in a prior lawsuit in gnized the ca- and yond the range of Congressional power which the United States had not been with and under the Constitution." Id. at 49, 34 S. joined as a party. Id. at 438, 46 S.Ct. state na- exceptions only, Ct. at 7. On this question, the Court con- 561. In reaching the conclusion that the cluded that since the Constitution ex- Pueblos were wards of the United States character, pressly authorized Congress to regulate whose lands could not be alienated with- at 617. commerce with the Indian tribes and pri- out its consent, the Court had occasion Court held that or judicial decisions had. affirmed the to construe the language "any tribe of be outside the power and duty of Congress to enact pro- Indians" in the Nonintercourse Act: not a tribe. tective legislation on behalf of dependent that, by the While there is no express reference Indian communities, United States even if the in the provision to Pueblo Indians, we Kagama, 118 U.S. 375, 384, 6 S.Ct. 1109, the Passama- think it must be taken as including 30 L.Ed. 228 (1886) Tiger V. Western uncivilized" In- them. They are plainly within its Investment Co., 221 U.S. 286, 315, 31 S. would apply. spirit and, in our opinion, fairly with- Ct. 578, 55 L.Ed. 738 (1911), the law Court's opinion in its words, "any tribe of Indians." banning the sale of liquor in Indian any suggestion Although sedentary, industrious, and country was a legitimate exercise of con- is a precondi- disposed to peace, they are Indians in gress' power. United States V. Sandov- race, customs and domestic govern- al, supra, 231 U.S. at 45-46, 34 S.Ct. 1. ment, always have lived in isolated the Sandoval The Court held that the determination communities, and are a simple, unin- That case in- by Congress that the Pueblos were a de- formed people, ill-prepared to cope course Act, but pendent Indian community entitled with the intelligence and greed of oth- ch. 109, 29 the benefits of protective legislation er races. It therefore is difficult to prohibiting presented a political question," upon believe that Congress in 1851 was not oxicating liquor which the Court was bound to uphold intending to protect them, but only Congress had the judgment of Congress unless the the nomadic and savage Indians then applicable to classification was so arbitrary as to con- living in New Mexico. A more rea- Indians as a stitute a usurpation of power. Id. at 47, sonable view is that the term "Indian of New Mexi- 34 S.Ct. 1. See United States V. Holli- tribe" was used in the acts of 1834 June 20, 1910, day, 70 U.S. (3 Wall.) 407, 419, 18 L.Ed. and 1851 in the sense of "a body of 182 (1865). Indians of the same or a similar race, United States V. Indian Nation V. In the Candelaria case, in 1926, the united in a community under one lead- Seneca Nation of Supreme Court reexamined for the first ership or government, and inhabiting time since Joseph the applicability to the a particular though sometimes ill-de- Pueblo Indians of the 1834 Noninter- fined territory." Montoya V. United 660 388 FEDERAL SUPPLEMENT States, 180 U.S. 261, 266, 21 S.Ct. 358, U.S. 564, 576, 28 S.Ct. 207, 53 L.Ed. 340 359 (45 L.Ed. 521). In that sense the (1908) United States V. Payne, 264 U. term easily includes Pueblo Indians. S. 446, 448-449, 44 S.Ct. 352, 68 L.Ed. Id. at 441-442, 46 S.Ct. at 563. 782 (1924); United States V. Celestine, There is nothing in this language which 215 U.S. 278, 290, 30 S.Ct. 93, 54 L.Ed. would indicate that the Nonintercourse 195 (1904). Act applies only to "federally recog- The Court holds that the Noninter- nized" Indians. Rather, Candelaria ap- course Act is to be construed as its plain pears to erase any doubt Joseph may meaning dictates and applies to the Pas- have created as to whether the all-inclu- samaquoddy Indian Tribe. sive language in the statute should be construed as its plain meaning dictates. 12 The Trust Relationship between the Unit- ed States and the Passamaquoddies [10] Finally, even if a latent ambi- under the Nonintercourse Act guity might be found in the statutory language, two cardinal principles of stat- [11] Defendants have rejected plain- utory construction buttress plaintiffs' tiffs' request for assistance on the position that the Nonintercourse Act ap- ground that no trust relationship exists plies to all Indian tribes in the United between the United States and the Pas- States, including the Passamaquoddies. samaquoddies. The Court disagrees. In The Supreme Court has consistently held the only decided cases to treat this issue, that language used in statutes confer- the Court of Claims has, in a series of ring benefits or protection on Indians decisions during the last ten years, de- must be construed in a nontechnical finitively held that the Nonintercourse sense, as the Indians themselves would Act imposes a trust or fiduciary¹ obli- have understood it, and that all ambigui- gation on the United States to protect ties in such statutes are to be resolved land owned by all Indian tribes covered in favor of the Indians. ,See, e. Gog by the statute: Seneca Nation of Indi- Squire V. Capoeman, 351 U.S. 1, 6-8, 76 ans United States, supra; United S.Ct. 611, 100 L.Ed. 883 (1956); Alaska States Oneida Nation of New York, Pacific Fisheries V. United States," 248 477 F.2d 939, 201 Ct.Cl. 546 (1973); Ft. U.S. 78, 89, 39 S.Ct. 40, 63 L.Ed. 138 Sill Apache Tribe V. United States, 477 (1918); Winters V. United States, 207 F.2d 1360, 1366, 201 Ct.Cl. -630 (1973). 12. Defendants also refer to the recent case primarily on Sandoval, ruled that since it did of Morton A. Mancari, 417 U.S. 535, 94 S.Ct. not have authority to recognize the plaintiffs 2474, 41 L.Ed.2d 290 (1974), and to an as a tribe, the action should be dismissed. unreported opinion letter of the District It is unclear from the letter whether the Court in Avalos V. Morton, Civil No. 9920 dismissal was based upon a fundamental mis- (D.N.M., September 10, 1974), as supporting reading of Sandoval or upon the failure of their contention that general Indian statutes the plaintiffs to establish that they were "in only apply to "federally recognized" tribes. fact an American Indian Tribe." (Letter of Mancari involved no issue of statutory con- court ,B) In the present case, it is struction. Instead, involved a Fifth stipulated that the Passamaquoddies are in Amendment Due Process challenge to the fact an Indian tribe. Indian Preference in Employment Act, 25 13. The courts have used interchangeably the U.S.C. § 472. The Supreme Court did no terms 'trust," "fiduciary," and "guardian- more than approve the constitutional validity ward". to describe the relationship between of the Indian preference as rationally related the Federal Government and the Indian "to the fulfillment of Congress' unique obli- tribes." E. g. Seminole Nation V. United gation toward the Indians." 417 U.S. at States, 316 U.S. 286, 296-297, 62 S.Ct. 1049, 555, 94 S.Ct. at 2485. The Avalos letter re- 86 L.Ed. 1480 (1942) Cherokee Nation V. sulted from the failure of counsel for the Georgia. 5 Pet. (30 U.S.) 1, 17, 8 L.Ed. 25 Indian plaintiffs to offer any brief or other (1831) United States V. Seminole Nation, argument on the issues in that case. Plain- 173 F.Supp. 784, 790-791, 146 Ct.Cl. 171 tiffs were suing for benefits afforded mem- (1959) Gila River Pima-Maricopa Indian bers of Indian tribes under the Snyder Act, Community V. United States, 140 F.Supp. 25 U.S.C. § 13. The District Court, relying 776, 780-781, 135 Ct.CL 180 (1956). JOINT TRIBAL COUN. OF PASSAMAQUODDY TRIBE V. MORTON 661 Cite as 388 F.Supp. 619 (1975) Ed. 340 These decisions are supported by a cen- ed, but it will protect you in all your 264 U. tury of federal Indian case law which just rights. But your great L.Ed. has recognized the existence of a fiduci- object seems to be, the security of lestine, ary relationship between the Federal your remaining lands; and have, L.Ed. Government and the Indian tribes. therefore, upon this point, meant to be The courts were first squarely sufficiently strong and clear, that, in oninter- presented with the question of the na- future, you cannot be defrauded of plain ture of the obligation, if any, imposed your lands that you possess the right he Pas- by the Nonintercourse Act in Seneca to sell, and the right of refusing to Nation of Indians V. United States, su sell your lands; that, therefore, the pra. In that case, the Senecas sued the sale of your lands, in future, will de- Unit- United States under the Indian Claims pend entirely upon yourselves. But Commission Act, 5-U.S.C. § 70a, claim- that, when you may find it for your ing damages arising out of four sales of interest to sell any part of your lands, plain- their New York lands at allegedly inade- the United States must be present, by the quate prices, to private parties. They their agent, and will be your security exists alleged that a representative of the that you shall not be defrauded in the Pas- United States was present at each of the bargain you may make. * In sales and that the United States That, besides the before mentioned se- issue, breached a fiduciary duty owed the tribe curity for your land, you will perceive, of by permitting the unconscionable trans- by the law of Congress for regulating actions. The Indian Claims Commission trade and intercourse with the Indian de- dismissed the claims on the ground that tribes, the fatherly care the United rcourse obli- the Federal Government was not respon- States intend to take of the Indians. protect sible for the transactions. The Court of American State Papers (In- covered Claims agreed as to the first sale, which dian Affairs, Vol. I, 1832), p. 142. Indi- took place in 1788 prior to the passage Id at 923-24 (emphasis in original). United of the Nonintercourse Act, but reversed This contemporary executive pronounce- York, as to the three later sales, which oc- ment. the court observed "plainly Ft. curred subsequent to the adoption of the show[s] the Federal Government as 477 Act in 1790. With respect to the Act, thenceforth the guardian and preserver (1973). the court began by noting that: of fairness to the Indians in their land dispositions." Id. at 924. After review- [T]he. requirement has always been it did ing prior judicial construction of the plaintiffs for federal consent and participation Act, the court concluded: ismissed. in any disposition of Indian real prop- the erty. From the beginning, this legis- In the light of its language, contempo- mis- lation has been interpreted as giving raneous construction, and history, we of "in the Federal Government a supervisory hold that the Trade and Intercourse were Letter of role over conveyances by Indians to Act created a special relationship be- it is others, in order to forestall fraud and tween the Federal Government and are in unfairness. Id. at 923. those Indians covered by the legisla- tion, with respect to the disposition of the The court then quoted at length from their lands, and that the United States guardian- President Washington's speech to the assumed a special responsibility to between Senecas in December 1790, shortly after Indian protect and guard against unfair the passage of the Act: United treatment in such transactions. Cf. 1049, Here, then, is the security for the The Oneida Tribe of Indians V. United Nation V. remainder of your lands. No State, States, 165 Ct.Cl. 487 (1964), cert. de- L.Ed. 25 no person, can purchase your lands, nied, 379 U.S. 946. [85 S.Ct. 441, 13 Nation, 171 unless at some public treaty, held un- L.Ed.2d 544] This responsibility was Indian der the authority of the United not merely to be present at the nego- F.Supp. States. The General Government will tiations or to prevent actual fraud, de- FORD never consent to your being defraud- ception, or duress alone; improvid- 468917 662 388 FEDERAL SUPPLEMENT ence, unfairness, the receipt of an un- exercise a duty, and knowledge and conscionable consideration would like- the failure to exercise the same duty. wise be of federal concern. Id. 477 F.2d at 944 (emphasis in origi- The concept is obviously one of nal; footnotes omitted). full fiduciary responsibility, not sole- These Court of Claims decisions are ly of traditional market-place morals. When the Federal Government under- consistent with an unbroken line of Su- takes an "obligation of trust" toward preme Court decisions which, from the an Indian tribe or group, as it has in beginning, have defined the fiduciary the Intercourse Act, the obligation is relationship between the Federal Gov- "of the highest responsibility and ernment and the Indian tribes as impos- trust," not that of "a mere contract- ing a distinctive obligation of trust upon ing party" or better business bureau. the Government in its dealings with the Cf. Seminole Nation V. United States, Indians. In the early case of Cherokee 316 U.S. 286, 296-97 [62 S.Ct. 1049, Nation V. Georgia, supra, 5 Pet. (30 U. 86 L.Ed. 1480] (1942). Id. 925. S.) at 17, 8 L.Ed. 25, Chief Justice Mar- shall described the condition of the Indi- [12] In Oneida Nation and Ft. Sill ans as "in a state of pupilage. Their re- Apache Tribe, the Court of Claims, in lation to the United States resembles unequivocal language, reaffirmed the that of a ward to his guardian." The holding of Seneca Nation 'that the following year, in Worcester V. Geor- Trade and Intercourse Act establishes a gia, 6 Pet. (31 U.S.) 515, 556, 8 L.Ed. fiduciary relationship between the Indi- 483 (1832), the same Chief Justice ob- ans and the United States Government." served that the laws enacted by Con- United States Oneida Nation of New gress for the protection of the Indians, York, supra, 477 F.2d at 942-943; Ft. and especially the Nonintercourse Act, Sill Apache Tribe V., United States, su- "manifestly consider the several Indian pra, 477 F.2d at 1366. Moreover, in nations as distinct political communities, Oneida Nation, the court made clear having territorial boundaries, within that by virtue of the fiduciary duty im- which their authority is exclusive, and posed by the Nonintercourse Act, the having a right to all the lands within United States has an obligation to do those boundaries, which is not only ac- whatever is necessary to protect Indian knowledged, but guarantied by the Unit- land when it becomes aware that Indian ed States." Fifty years later, in United rights have been violated, even though States V. Kagama, supra, 118 U.S. at the United States did not participate in 383-384, 6 S.Ct. at 1114, the Court reaf- the unconscionable transaction firmed that "[t]hese Indian tribes are The Government would argue that the the wards of the nation. They are com- absence of participation in the re- munities dependent on the United maining twenty-three (23) treaties States. From their very leases it from any fiduciary duty that weakness and helplessness, so largely might have existed. Although the due to the course of dealing of the Fed- Government did not actually partici- eral Government with them and the pate in the remaining treaties, we treaties in which it has been promised, hold the fiduciary relationship would there arises the duty of protection, and continue to exist if the Government with it the power." (emphasis in origi- had either actual or constructive nal). Again, in Tiger V. Western In- knowledge of the treaties. With such vestment Co., supra, 221 U.S. at 310, 31 knowledge, if the Government subse- S.Ct. at 584, the Court stated, " quently failed to protect the rights of the Congress of the United States has the Indians, then there would be a undertaken from the earliest history of breach of the fiduciary relationship. the Government to deal with the Indians This court does not see any distinction as dependent people and to legislate con- between participation and failure to cerning their property with a view to JOINT TRIBAL COUN. OF PASSAMAQUODDY TRIBE V. MORTON 663 n Cite as 388 F.Supp. 649 (1975) nowledge and their protection as such." More recent- Congress to restrict the alienation of In he same duty. ly, in Seminole Nation V. United States, dian land is justified only by the exis- hasis in origi- n.13 supra, 316 U.S. at 297, 62 S.Ct. at tence of the guardian-ward relationship 1055, the Court recognized that the between. the Federal Government and United States has charged itself with the Indian tribes E. g., Sunderland V. decisions are moral obligations of the highest respon- United States, 266 U.S. 226, 233-234, 45 en line of Su- sibility and trust. Its conduct, as dis- S.Ct. 64, 69 L.Ed. 259 (1924) Brader nich, from the closed in the acts of those who represent V. James, 246 U.S. 88, 98, 38 S.Ct. 285, the fiduciary it in dealings with the Indians, should 62 LEd. 591 (1918); Tiger V. Western Federal Gov- therefore be judged with the most exact- Investment Co., supra, 221 U.S. at 316, ribes as impos- ing fiduciary standards. Finally, in 31 S.Ct. 578; Lone Wolf V. Hitchcock, a of trust upon Federal Power Commission V. Tuscarora 187 U.S. 553, 565, 23 S.Ct. 216, 47 L.Ed. alings with the Indian Nation, supra, 362 U.S. at 119, 299 (1903) Cherokee Nation V. Hitch- se of Cherokee 80 S.Ct. at 555, the Supreme Court said cock, 187 U.S. 294, 306-308, 23 S.Ct. 5 Pet. (30 U. with specific reference to the Noninter- 115, 47 Ed. 183 (1902) United States ef Justice Mar- course Act: Kagama, supra, 118 U.S. at 384,14 6 ion of the Indi- The obvious purpose of that statute is S.Ct. 1109. lage. Their re- to prevent unfair, improvident or im- tates resembles [13, 14] In view of the foregoing, proper disposition by Indians of lands uardian." The the conclusion must be that the Nonin- owned or possessed by them to other tercourse Act establishes a trust rela- cester V. Geor- parties, except the United States, 5, 556, 8 L.Ed. tionship between the United States and without the consent of Congress, and nief Justice ob- the Indian tribes, including the to enable the Government, acting as nacted by Con- Passamaquoddies,¹ to which it applies. parens patriae for the Indians, to va- The Court holds that defendants erred of the Indians, cate any disposition of their lands ntercourse Act, in denying plaintiffs' request for litiga- made without its consent. several Indian tion on the sole ground that no trust re- The Court of Claims decisions are also cal communities, lationship exists between the United ndaries, within supported by numerous Supreme Court States and the Passamaquoddy Indian 5 exclusive, and cases which have held that the power of Tribe. he lands within 14. The imposition of a legal incapacity com- relationship with the tribe. United States V. is not only ac- bined with an undertaking to ensure fairness Santa Fe Pacific R. Co., supra, 314 U.S. at pied by the Unit- in transactions involving the incapacitated 346, 62 S.Ct. 248 United States V. Nice, later, in United party's property constitutes the most literal 241 U.S. 591, 599, 36 S.Ct. 696, 60 L.Ed. ra, 118 U.S. at kind of guardianship. 1192 (1916). See also Menominee Tribe of the Court reaf- A guardian of the property of person Indians V. United States, 391 U.S. 404, 412- who is under an incapacity is a trustee in 413, 88 S.Ct. 1705, 20 L.Ed.2d 697. (1968). ndian tribes are the broad sense of the term. He is under Congress has never expressly terminated its They are com- a duty to his ward to deal with the prop- relationship with the Passamaquoddy Tribe, on the United erty for the latter's benefit. Like a trus- and the mere fact that the Federal Govern- om their very tee a guardian is a fiduciary. He is not, ment has not objected to Maine's under- however, a trustee in the strict sense. He taking certain obligations for the Protec- ness, so largely is entrusted with the possession and man- tion of the Passamaquoddies does not evi- aling of the Fed- agement of his ward's property but he dence such a clear and unequivocal Congres- them and the does not take titlexto it. Scott, Law of sional intent as will support a finding of ter- S been promised, Trusts (3rd 1967) $7 at 71. mination. f protection, and 15. While apparently not denying that the 16. Whether the United States breached its mphasis in origi- Nonintercourse Act may have at one time fiduciary duty to plaintiffs by refusing to protected the Passamaquoddies, intervenor V. Western In- bring suit against the State of Maine for the argues that the Federal Government has redress of alleged violations of the Noninter- 1 U.S. at 310, 31 since terminated its obligations toward the course Act is a question not presently before stated, " Passamaquoddies by acquiescing in Maine's the Court. In the present action plaintiffs United States has assumption of responsibility for the Tribe. seek no more than a declaratory judgment It is clear, however, that termination of the arliest history of that defendants erred in denying their re- Federal Government's responsibility for an with the Indians quest solely on the erroneous legal ground Indian tribe requires plain and unambigu- that no trust relationship exists between the d to legislate con- ous" action evidencing a clear and unequivo- United States and the Passamaquoddies. with a view to cal intention of Congress to terminate its However, to the effect that the Govern- 664 388 FEDERAL SUPPLEMENT The Affirmative Defenses Power Commission V. Tuscarora Indian Defendants and intervenor have raised Nation supra; Sioux Indians V. United a number of affirmative defenses, which States, 277 U.S. 424, 48 S.Ct. 536, 72 L. they assert preclude the Court from rul- Ed. 939 (1928) Lone Wolf V. Hitch- ing upon the substantive issues present- cock, supra. There is no dispute in this ed by the action. The Court finds these case that Gongress has the power under to be without merit. the Commerce Clause to pass protective legislation on behalf of the Passama- [15] The Political Question Doc- quoddy Tribe; nor is there any claim trine. Intervenor contends that the that application of the Nonintercourse Court lacks jurisdiction of the action be- Act to the Passamaquoddies would vio- cause it presents a nonjusticiable "politi- late any prior treaty commitment. The cal question." Baker V. Carr, 369 U.S. only issue before this Court is whether 186, 82 S.Ct. 691, 7 L.Ed.2d 663 (1961). Congress, once having exercised its pow- The position is that "the scope and na er to pass protective legislation on behalf ture of federal responsibility over Indi- of the Indians, meant to include the Pas- an tribes is not a matter for the courts samaquoddies. This presents a question to determine. The decisions cited as of legislative intent, which has always authority for this proposition, however, been for resolution by the courts. See, deal solely with the power of Congress g., Morton V. Ruiz, 415 U.S. 199, 212- to legislate with respect to Indians. 229, 94 S.Ct. 1055, 39 L.Ed.2d 270 They fall into two categories: (1) cases (1974). It is clear that this case in which the constitutional power of presents no nonjusticiable political ques- Congress to enact legislation respecting tion a particular group of Indians is chal- lenged on the ground that the group is [16, 17] The vailability of Review not an 'Indian tribe" within the mean- under the Administrative Procedure Act. ing of the Commerce Clause Board of The defendants and intervenor assert Commissioners V. Seber, 318 U.S. 705, that defendants' refusal to institute suit 63 S.Ct. 920, 87 L.Ed. 1094 (1943) on behalf of the Passamaquoddies United States V. McGowan, 302 U.S. 535, against the State of Maine is not subject 58 S.Ct. 286, 82 L.Ed. 410 (1938); to judicial review under the provisions United States V. Ramsey, 271 U.S. 467, of the Administrative Procedure Act, 5 46 S.Ct. 559, 70 L.Ed. 1039 (1926) U.S.C. § 701 et seq. Their argument is United States V Nice, 15 supra; Pep- twofold. First, they contend that de- rin V. United States, 232 U.S. 478, 34 S. fendants' action is not "final agency ac- Ct. 387, 58 L.Ed. 691 (1914) ; United tion" reviewable. under 5 U.S.C. §-704. States V Sandoval, supra; Tiger V. While they concede that the decision of Western Investment Co., supra, United the Attorney General was final action, States V. Rickert, 188 U.S. 432, 23 S.Ct. they argue that the decision of the Sec- 478, 47 L.Ed. 532 (1903) United States retary of the Interior not to recommend V. Holliday, supra; see also Baker V. litigation must be "treated separately" Carr, supra, 369 U.S. at 282, 82 S.Ct. and that, so regarded, the Secretary's 691 (Frankfurter, J., dissenting); and determination is not judicíally-review- (2) cases which hold that Congressional able final action. The record before the action involving the administration of Court clearly establishes, however, that Indian affairs is not subject to judicial the Attorney General relied exclusively challenge on the ground that it violates on the recommendation of the Secretary previous treaty commitments. Federal in making his decision 17 and that the ment's obligation may include the duty to lit- 17. The Court rejects as specious defendants' igate, see Mason v. United States, 461 F.2d argument that, because the Notice filed by 1364, 1372-1373, 198 Ct.CL 599 (1972), the defendants with this Court on June 22, rev'd on other grounds, 412 U.S. 391, 93 S. 1972 (p. 6 supra) stated that the Attorney Ct. 2202, 37 L.Ed.2d 22 (1973). General's decision not to bring suit was GERALD JOINT TRIBAL COUN. OF PASSAMAQUODDY TRIBE V. MORTON 665 Cite as 388 Supp. 649 (1975) uscarora Indian actions of the Attorney General and the 519, and that judicial review of his exer- idians V. United Secretary were but two stages of a sin- cise of that discretion is barred by the S.Ct. 536, 72 L. gle administrative process. In the in- doctrine of prosecutorial discretion. Wolf V. Hitch- stant action, plaintiffs seek review of United States V. Nixon, 417 U.S. 418, dispute in this the result of this combined administra- 683, 94 S.Ct. 3090, 41. L.Ed.2d 1039 the power under tive determination. Furthermore, there (1974) Newman V. United States, 127 pass protective is concededly a final order before the U.S.App.D.C. 263, 382 .2d 479, 480-481 the Passama- Court, and the Administrative Procedure (1967); Smith V. United States, 375 F. there any claim Act, 5 U.S.C. $ 704, expressly provides 2d 243, 246-247 (5th Cir. 1967) ; In- Nonintercourse that an "intermediate agency action or mates of Attica Correctional Facility V. ddies would vio- ruling not directly reviewable is subject Rockefeller, 477 F.2d 375, 379-382 (2d mmitment The to review on the review of the final Cir. 1973); Weiss V. Morgenthau, 233 court is whether agency action." The cases cited by de- F.Supp. 307, 308 (S.D.N.Y.1964), aff'd xercised its pow- fendants, Chicago and Southern Air per curiam, 344 F.2d 428 (2d Cir. slation on behalf Lines V. Waterman Steamship Corp., 333 1965) ; Application of James, 241 F. include the Pas- U.S. 103, 112-113, 68 S.Ct. 431, 92 L.Ed. Supp. 858, 860 (S.D.N.Y.1965) ; Boyd V. sents question 568 (1948), and Federal Power Gommis- United States, 345 F.Supp. 790, 794 (E. hich has always sion V. Hope Gas Co., 320 U.S. 591, 619, D.N.Y.1972). 19 This contention is based the courts. See, 64 S.Ct. 281, 88 L.Ed. 333 (1944), in on two fundamental misconceptions. In U.S. 199, 212- volved attempts to review an intermedi- the first place, plaintiffs de not ask this L.Ed.2d 270 ate stage of administrative action with- Court to order the Attorney General to that this case out reviewing the ultimate stage; they bring suit on their behalf in the political ques- are inapposite where the ultimate action present action, plaintiffs seek only a de- is itself being reviewed. claratory judgment that the Noninter- course Act establishes a trust relation- of Review [18] The second argument presented ship between the United States and the Procedure Act. by defendants and intervenor as pre- tervenor assert Passamaquoddies. In the second place, venting judicial review under the Ad- to institute suit the doctrine of prosecutorial discretion ministrative Procedure Act is that de- cannot shield legal error. As the court Passamaquoddies fendants' action constitutes "agency ac- is not subject stated in Nader V. Saxbe, 497 F.2d 676, tion committed to agency dis- the provisions 679-680 19 (D.C.Cir.1974), cretion by law," 5 U.S.C. § 701(a) (2). Procedure Act, 5 The thrust of the argument is that the It would seem to follow that the exer- argument is Attorney General has absolute discretion cise of prosecutorial discretion, like ontend that de- to institute litigation, 28 U.S.C. §§ 516, the exercise of Executive discretion agency ac- U.S.C. § 704. made "consistent with" the Secretary's de protecting Indian land and administering the decision of termination that no trust relationship exists, government policy pursuant to statutes such final action, that was not the sole basis for the Attorney as the Nonintercourse Act. See, e. g., Hynes General's decision. The Notice incorporated V. Grimes Packing Co., 337 U.S. 86, 96-97, of the Sec- the determination of the Interior Depart 69 S.Ct. 968, 93 L.Ed. 1231 (1949) Boles V. to recommend ment and stated that, consistent with that Greenville Housing Authority, 468 F.2d 476, separately" decision, the Justice Department was declin- 479 (6th Cir. 1972). the Secretary's ing to institute the action requested by plaintiffs. The Notice was filed in response 19. Similarly, intervenor cites several cases udicially-review- to the Court's order of June 16, 1972 direct- which stand merely for the proposition that record before the ing defendants, in the event their decision 25 U.S.C. § 175 (requiring that the United however, that was to deny plaintiffs' request, to state their States Attorney "shall" represent all Indians exclusively reasons for so deciding. The only reason in all suits at law and equity) does not im- of the Secretary stated in the Notice is the Secretary's deter- pose a mandatory duty. Rincon Band of mination that no trust relationship exists. Mission Indians V. Escondido Mutual Water 17 and that the It is clear that the Attorney General adopt- Co., 459. F.2d 1082, 1084-1085 (9th Cir. ed the Secretary's determination as his only 1972) United States v. Gila River Pima- pecious defendants' reason for declining to bring suit. Maricopa Indian Community, 391 F.2d 53, 56 he Notice filed by (9th Cir. 1968) Siniscal V.'s United States, Court on June 22, 18. The defendant Secretary is a proper party 208 F.2d 406, 410 (9th Cir. 1953), cert. de- that the Attorney because the Department of the Interior is nied, 348 U.S. 818, 75 S.Ct. 29, 99 L.Ed. 645 bring suit was the federal agency primarily responsible for (1954). 388 F.Supp.-42½ 666 388 FEDERAL SUPPLEMENT generally, is subject to statutory and Powell sought both a declaratory judg- constitutional limits enforceable ment that the House of Representatives through judicial review. The law has could not constitutionally prevent him long recognized the distinction be- from taking his seat because of prior tween judicial usurpation of discre- misconduct, and a writ of mandamus or tionary authority and judicial review an injunction to compel officers and em- of the statutory and constitutional ployees of the House to seat him. The limits to that authority. Judicial re- District Court dismissed the complaint, view of the latter sort is normally and the Court of Appeals affirmed on available unless Congress has express- the grounds that the case was not justi- ly withdrawn it. (citations omitted). ciable because the requested coercive re- See also Boyd V. United States, supra, lief would bring the judiciary into open 345 F.Supp. at 792-793. Where, as in conflict with a coordinate branch and a the present case, the decision of an ad- declaratory judgment would "not finally ministrative official is based upon an er- terminate the controversy." Powell V. roneous legal conclusion, the courts have McCormack, 129 U.S.App.D.C. 354, 395 an obligation to correct the error so that F.2d 577, 597 (1968). The Supreme he may exercise his discretion based Court reversed and remanded the case to upon a correct understanding of the law. the District Court with instructions to Perkins V. Elg, 307 U.S. 325, 349-350, enter a declaratory judgment for Powell 59 S.Ct. 884, 83 L.Ed. 1320 (1939); Se- and to consider other appropriate reme- curities and Exchange Commission V. dies. With respect to the defendants' Chenery Corp., 318 U.S. 80, 94, 63 S.Ct. claim of nonjusticiability because the 454, 87 Ed. 626 (1943) McGrath V. Court lacked power to grant coercive re- Kristensen, 340*U.S. 162, 168-171, 71 S. lief, the Court said: Ct. 224, 95 L.Ed. 173 (1950). See 5 U. We need express no opinion about S.C. § 706. Cf. Citizens to Preserve the appropriateness of coercive relief Overton Park, Inc. V. Volpe, 401 U.S. in this case, for the petitioners sought 402, 410, 91 S.Ct. 814, 28 L.Ed.2d 136 declaratory judgment, a form of relief (1971), Abbott Laboratories V. Gard- the District Court could have issued. ner, 387 U.S. 136, 140-141, 87 S.Ct. The Declaratory Judgment Act, 28 U. 1507, 18 L.Ed.2d 681 (1967). S.C. § 2201, provides that a district The Administrative Procedure Act court may "declare the rights of any interested party does not bar judicial review of defend- whether or not further re- ants' action. lief is or could be sought." The avail- [19] The Propriety of Declaratory ability of declaratory relief depends Relief. Intervenor contends that since on whether there is a live dispute be- the Court is without authority to compel tween the parties, and a request for the Attorney General to file suit on be- declaratory relief may be considered half of plaintiffs, the prayer for declara- independently of whether other forms tory relief is merely an effort to obtain of relief are appropriate. We thus an advisory opinion, which the Court conclude that in terms of the general should decline to render. See Sierra criteria of justiciability, this case is Club V. Morton, 405 U.S. 727, 732 n. justiciable. 395 U.S. at 517-518, 89 92 S.Ct. 1361, 31 L.Ed.2d 636 (1972) S.Ct. at 1962 (citations omitted). Public Service Commission V. Wycoff It is thus clear that plaintiffs are not Co., 344 U.S. 237, 241, 73 S.Ct. 236, 97 barred from declaratory relief merely L.Ed. 291 (1952). Intervenor's argu- because this Court may not be able to ment is identical to that rejected by the fashion coercive relief. See also Perkins Supreme Court in Powell V. McCormack, V. Elg, supra, 307 U.S. at 349-350, 59 S. 395 U.S. 486, 89 S.Ct. 1944, 23 L.Ed.2d Ct. 884; McGrath V. Kristensen, supra, 491 (1969). In that case, Adam Clayton 340 U.S. at 168-171, 71 S.Ct. 224. JOINT TRIBAL COUN. OF PASSAMAQUODDY TRIBE V. MORTON 667 Cite as 388 F.Supp. 649 (1975) laratory judg- In 1783 and 1784 Allan wrote several :epresentatives Judgment will be entered for the letters to the Federal Government in prevent him plaintiffs declaring that the Indian Non- which he indicated that the Passama- cause of prior intercourse Act, 25 U.S.C. § 177, is ap- quoddy Indians had greatly assisted the mandamus or plicable to the Passamaquoddy Indian American cause and urged Congress to ficers and em- Tribe; that the Act establishes a trust fulfill the promises he had made on be- seat him. The relationship between the United States half of the Government, especially with the complaint, and the Tribe; and that defendants may respect to protecting Passamaquoddy S affirmed on not deny plaintiffs' request for litiga- hunting gròunds. Congress failed to act was not justi- tion in their behalf on the sole ground on Allan's recommendations, and on ed coercive re- that there is no trust relationship be- March 5, 1784, Allan's appointment was ciary into open tween the United States and the Tribe. revoked pursuant to a resolution of the branch and a Plaintiffs may submit a proposed form Continental Congress revoking the ap- ild "not finally of decree, with notice to defendants, pointments of all Indian Superintend- Powell V. within ten days. Defendants may ents. 354, 395 present their comments thereon within The Supreme 3. In 1793 the same John Allan ap- five days thereafter. ded the case to peared before the Massachusetts General instructions to It is so ordered. Court. He reported that during the ent for Powell Revolutionary War the Passamaquoddy propriate reme- APPENDIX Tribe had relinquished their claims to be defendants' land in Massachusetts on the condition because the that the United States would confirm coercive re- the Tribe's right to inhabit, unmolested, Contacts between the Federal Govern- certain parcels of their aboriginal terri- ment and the Passamaquoddy opinion about Tribe since 1776 tory coercive relief 4. In 1819 Congress passed legislation 1. On December 24, 1776, George itioners sought entitled, "An Act making provision for Washington wrote to the Passamaquod- form of relief the civilization of the Indian tribes ad- dy Tribe and told them that he was glad have issued. joining the frontier settlements.' Act to hear that the Tribe had accepted the Act, 28 U. of March 3, 1819, 3 Stat. 516. In 1824, chain of friendship which he sent in that a. district using funds appropriated pursuant to February 1776, and warned the Tribe the rights this Act, the Federal Government con- against turning against the United terested party tributed $233.00 to the Tribe, an amount States. further re- which covered one-third of the cost of The avail- 2. John Allan served as the Continental the construction of a school. From 1824 relief depends Congress' agent to the Indians of the to 1828 the Federal Government used dispute be- Northeast during the American Revolu- funds appropriated pursuant to the 1819 request for tionary War. Appointed in 1777, he was Act to contribute $250.00 a year to Eli- be considered instructed to enlist the support of the jah Kellogg, a missionary to the Indians, other forms Indian tribes for the American colonies. who sought to establish and maintain a We thus In May 1777 Allan met with the Passa- school for the Passamaquoddies. In of the general maquoddy and St. John's Tribes. In 1829 the Government withheld funds for this case is recognition of Allan's promises that the the school because of intra-tribal dis- 517-518, 89 Tribe would be given ammunition for putes concerning the religion of the Su- omitted). hunting, protection of their game and perintendent. In December 1829 two intiffs are not hunting grounds, regulation of trade to leaders of the Passamaquoddy Tribe, relief merely prevent imposition, the exclusive right Deacon Sockbason and Sabattis Neptune, not be able to to hunt beaver, the free exercise of reli- met in Washington with Thomas L. See also Perkins gion, a clergyman, and the appointment McKenny, Director of the Office of In- 349-350, 59 S. of an agent for their protection and sup- dian Affairs, and John H. Eaton, Secre- istensen, supra, port in time of need, the Passamaquoddy tary of War, seeking a reinstatement of 224. Tribe pledged their support to the colo- the funds for the school, money to hire a nies. priest, and a parcel of land. Although 668 388 FEDERAL SUPPLEMENT the funds for the school were temporari- land where they could "assemble unmo- ly reinstated and money for a priest was lested." In response to the petition, the provided, all funds were permanently Massachusetts: Legislature appointed a terminated in 1831 because of the con- committee to assign land to the Passa- tinuation of sectarian strife. maquoddy Indians. Treaty negotiations 5. In December 1829 President Jackson began in 1793, and on September 24, 1794 Massachusetts and the Passama- requested funds from Congress to pur- chase additional land for the Passama- quoddy Tribe entered into a treaty. quoddy Tribe. Congress failed to act on John Allan, the former Federal Indian the President's request. agent, was one of the members of the committee appointed by the Massachu- 6. In July 1832 the Commissioner of Indian Affairs, Elbert Herring, denied setts Legislature, and his name appears as one of the signers of the treaty for Kellogg's request for funds for the im- Massachusetts. By the terms of the provement of Passamaquoddy agricul- treaty, the Passamaquoddy Tribe sur- ture. rendered all claims to land in the terri- 7. During the period 1899 to 1912, five tory of Massachusetts in exchange for a members of the Passamaquoddy Tribe conveyance of 23,000 acres of land at In- attended the Carlisle Indian School at dian Township, ten acres of land at Carlisle, Pennsylvania. In 1970 a mem- Pleasant Point, and the exclusive right ber of the Passamaquoddy Tribe gradu- to fish and hunt the Schoodic River, all ated from Haskel Indian College at in the District of Maine. Seven years Lawrence, Kansas later, in 1801, Massachusetts assigned 8. Since 1965 the Tribe has received an additional 90 acres of land at Pleas- funds from the Department of Housing Point to the Tribe. and Urban Development, the Office of 3. In 1819 Massachusetts passed legis- Economic Opportunity and Federal lation commonly known as the Articles agencies other than the Department of of Separation, which provided for the the Interior. Although eligibility for establishment of Maine as a separate such assistance has been determined by State. Under the Articles of Separation criteria applicable to all citizens, in Maine agreed to "assume and perform many instances the funds were taken all duties and obligations of the Com- from special Indian allocations or were monwealth, towards the Indians within administered by special Indian desks said District of Maine, whether the within the various agencies. same arise from treaties or otherwise, See n. 2, supra. II Contacts between the States of Massa- Maine Contacts chusetts and Maine and the Passa- 4. Since its admission as a State in maquoddy Tribe since 1776 Massa- 1820, Maine has enacted approximately chusetts Contacts 350 laws which relate specifically to the 1. On July 19, 1776, the Governor of Passamaquoddy Tribe. This legislation Massachusetts on behalf of Massachu- includes 72 laws providing appropria- settş and the other states entered into a tions for or regulating Passamaquoddy treaty of alliance and friendship with agriculture; 33 laws making provision* delegates from the St. John's and Mic- for the appropriation of necessities, mac Tribes in which the Indian dele- such as blankets, food, fuel, and gates agreed to use their influence to wood, for the Tribe; 85 laws relating to convince the Passamaquoddy and other educational services and facilities for tribes to supply men for George Wash- the Tribe; 13 laws making provision for ington's army. the delivery of health care services and 2. In 1792 leaders of the Passamaquod- facilities to the Tribe; 22 laws making dy Tribe petitioned Massachusetts for allowance for Passamaquoddy housing JOINT TRIBAL COUN. OF PASSAMAQUODDY TRIBE V. MORTON 669 Cite as 388 Supp. 649 (1975) mble unmo- (Me.Const. art. 9, $ 14-D, authorizes the d. In 1954 an amendment to the petition, the Legislature to make available a fund not Maine Constitution, Const. art. appointed to exceed $1,000,000.00 for the purpose 2, § 1, extended the franchise to of insuring mortgages on homes owned, Indians. 22 M.R.S.A. § 4831, as the Passa- negotiations "by members of the 2 tribes on several amended, P.L.1973, ch. 104, au- ptember 24, Indian reservations") 54 laws making thorizes an official tribal govern- he Passama- special provision for Indian indigent re- ment. This statute provides that lief; 54 laws relating to the improve- each Passamaquoddy reservation 0 a treaty. deral Indian ment and protection of roads and water shall have a governor, lieutenant nbers of the on the Passamaquoddy reservation; and governor, and six-man tribal coun- e Massachu- 15 laws providing for the legal represen- cil. It further provides that each tation of the Tribe and its members. reservation shall elect, on an alter- name appears he treaty for nate basis, a representative to the 5. The following is a representative erms of the State Legislature to serve as the sample of Maine statutes currently in Passamaquoddy representative. y Tribe. sur- effect providing for the welfare and pro- in the terri- tection of the Passamaquoddy Tribe. e. 22 M.R.S.A. 4702, as amended xchange for a P.L.1971, ch. 544, establishes a of land at In- Beginning in 1823 Maine has ad- Department of Indian Affairs, S of land at ministered trust funds on behalf which is under the control and su- xclusive right of the Passamaquoddy Tribe. 22 pervision of the Commissioner of odic-River, all M.R.S.A. § 4834, as amended, P. Indian Affairs. 22 M.R.S.A. $ Seven years L.1973, ch. 141, creates a trust 4733, as adopted, P.L.1967, ch. setts assigned fund out of the annual net pro- 252, eff. May 8, 1967, provides for land at Pleas- ceeds from the sale of timber and the creation of an Indian Housing grass taken from Indian Town- Authority. S passed legis-, ship. This statute permits the as the Articles tribal council to determine the f. Maine has always retained a vari- manner in which a certain per- ety of miscellaneous laws which ovided for the as a separate centage of the funds shall be ex- affect various aspects of Passama- s of Separation pended quoddy tribal life. For instance, le and perform current Maine statutes permit b. 22 M.R.S.A. § 4707 renders void is of the Com- members of the Tribe to obtain any contract made by an Indian Indians within for the sale or disposal of trees, free hunting and fishing licenses, whether the timber, or grass on Indian lands. 12 M.R.S.A. § 2401-B(7), as or otherwise, amended, P.L.1973, ch. 92; forbid c. 22 M.R.S.A. § 4709 authorizes the any person from keeping Indian Attorney General, on his own ini- skeletons or bones for more than a acts tiative or at the request of a year without returning them to Tribe, to sue in the name of the as a State in Tribe in actions for money owed the Tribe for burial, 22 M.R.S.A. d approximately the Tribe for injuries done to 8 4720, as adopted, P.L.1973, ch. ecifically to the tribal land. The damages re- 788, §§ 95, 96, eff. April 1, 1974; This legislation covered by such a suit are to be and impose a $250.00 fine upon ding appropria- distributed by the Commissioner any person who poses as an Indian Passamaquoddy of Indian Affairs, or invested in for the purpose of vending goods aking provision useful articles. or wares, 22 M.R.S.A. § 4715. of necessities, ood, fuel, and laws relating to facilities for provision for care services and 22 laws making aquoddy housing Ch. 5 PROTECTION OF INDIANS 25 § 177 Land Office, fixed the lines which control- not conveying the bed of such river in- led the court when a question arose as to terferes with no object or purpose of the whether a claimant was within or with- grant. U. S. V. Mackey, D.C.Okl.1913, 214 out the particular reservation at the time F. 137, appeal of certain parties dismiss- of alleged depredation. French V. U. S., ed 216 F. 129, 132 C.C.A. 373, and decree 1914, 49 Ct.Cl. 337. reversed on other grounds 216 F. 126, 132 C.C.A. 370. 3. Division of tribal lands among mem- bers, surveys for 5. Errors in surveys To accomplish the object of legislation Where in making the survey of the by which Congress provided for the land ceded by the United States to the eventual dissolution of certain tribes such Choctaw Nation under the treaties of 23 the Creek nation and the division of 1820 and 1825, 7 Stat. 210, 234, an error 2 large portion of the tribal lands among was made in running the eastern bound- the members of the tribe, it was neces- ary of said lands in that the surveyor sary under this section to survey and sub- bore to the west and did not cover in the divide such lands, in like manner as pub- actual survey all the lands ceded to the lic lands are divided. U. S. V. Mackey, D. Choctaws; and where said error was not C.Ok!.1913, 214 F. 137. discovered until a resurvey was made in 1857 pursuant to the provisions of the & Title to Arkansas River bed, grant to Treaty of 1855, 11 Stat. 611, the tract of Creek tribe as carrying land was not legally taken until after the The grant of lands in Indian Territory Treaty of 1853. Chickasaw Nation V. to the Creek Tribe of Indians by patent U. S., 1942, 94 Ct.Cl. 213. of Aug. 11, 1852, did not vest the tribe with any right or title to the bed of the Where the Commissioner of Indian Af- Arkansas river between high-water marks, fairs, after the report of the error in the but the same remained in the United 1825 survey as discovered in the survey States and passed to the state of Okla- of 1857, decided to stand by the original homa on its admission, subject to such survey; and where Congress by Act Mar. rights as were given by its laws to own- 3, 1875, 18 Stat. 476, ratified the original ers of lands bordering on the stream but marking, because the original erroneous the purpose of such grant to the Creeks boundary was to be recognized by the was to provide them a home in the then Government it was not intended by Con- far West so long as they should exist as gress that the Government should not ac- 2 tribe and continue to occupy the lands count to the rightful owners for the prop- granted and to construe such grant as erty wrongfully taken. Id. § 177. Purchases or grants of lands from Indians No purchase, grant, lease, or other conveyance of lands, or of any title or claim thereto, from any Indian nation or tribe of Indians, shall be of any validity in law or equity, unless the same be made by treaty or convention entered into pursuant to the Constitution. Every person who, not being employed under the authority of the United States, attempts to negotiate such treaty or convention, di- rectly or indirectly, or to treat with any such nation or tribe of Indians for the title or purchase of any lands by them held or claimed, is liable to a penalty of $1,000. The agent of any State who may be present at any treaty held with Indians under the au- thority of the United States, in the presence and with the approba- tion of the commissioner of the United States appointed to hold the same, may, however, propose to, and adjust with, the Indians the compensation to be made for their claim to lands within such State, which shall be extinguished by treaty. R.S. § 2116. Historical Note Derivation. Act June 30, 1834, c. 161, $ 12, 4 Stat. 730. Cross References the Patents to be held in trust; descent and partition, see section 348 of this ti- FORD 139 GERALD 370 528 FEDERAL REPORTER, 2d SERIES These were a medical certificate stating prerequisite. Since no evidence of that that petitioner was suffering from tu- was presented, it was not an abuse of berculosis, a service memo, and a call-in discretion to deny him the status of vol- letter addressed to him in Mexico. He untary departure. contends that it was error to admit them The petition for review of the Serv- because they lacked probative value and ice's order of deportation is denied and their authors were not present at the the order is affirmed. hearing. Since the documents tended to corrob- orate a key portion of the statement in SWORT KEYNUMBERSYSTEM Form 1-213, petitioner's return to Mexi- 8 in 1961 for health reasons, their rele- vance is undeniable. Nor does the lack of foundation testimony by live witness- es in a deportation hearing necessitate reversal. Hernandez V. INS, 498 F.2d JOINT TRIBAL COUNCIL OF the 919, 921 (9th Cir. 1974); Marlowe V. INS, PASSAMAQUODDY TRIBE et al., 457 F.2d 1314, 1315 (9th Cir. 1972). Plaintiffs-Appellees, Without evidence to indicate the need to V. have these witnesses present, we cannot say that their absence was so fundamen- Rogers C.B. MORTON, Secretary, tally unfair so as to violate due process. Department of the Interior, et al., Our standard on review of a de- Defendants-Appellees, portation order, fixed by 8 U.S.C. State of Maine, Intervenor-Appellant. § 1105a(a)(4), is limited to determining that the agency's order is supported by JOINT TRIBAL COUNCIL OF the reasonable, substantial, and probative ev- PASSAMAQUODDY TRIBE et al., idence on the record considered as a Plaintiffs-Appellees, whole. Lavoie, 418 F.2d at 735. From V. the Form 1-213 and the corroborative documents it was found that petitioner Rogers C. B. MORTON, Secretary, left the United States in 1961 and re-en- Department of the Interier, et al., tered in 1972 without inspection or prop- Defendants-Appellants. er documentation. This finding is sup- Nos. 75-1171, 75-1172. ported by substantial, probative evidence and will not be overturned by this court. United States Court of Appeals, First Circuit. [7] Under 8 U.S.C. § 1361, petitioner FORD bore the burden of proof on the issue of Argued Sept. 11, 1975. legal entry. Since he offered no evi- Decided Dec. 23, 1975. dence to rebut the evidence of illegal LIBRARY entry in 1972, the order of deportability must be affirmed. Action was brought by the joint [8,9] Petitioner also appeals the de- tribal council of the Passamaquoddy In- nial of the privilege of voluntary depar- dian Tribe and the tribe's two governors ture. 8 U.S.C. § 1254(c). He presented against federal officials for a declaratory no evidence in support of his eligibility, judgment as to the applicability of the contending that there existed sufficient Indian Nonintercourse Act to the tribe. information in his administrative file to The state of Maine intervened as a party support the application. The petitioner defendant. Judgment was given for the bears the burden of proof to establish Indians in the United States District eligibility for voluntary departure. Kha- Court for the District of Maine, Edward laf V. INS, 361 F.2d 208 (7th Cir. 1966). Thaxter Gignoux, J., 388 F.Supp. 649, Good moral character of the alien is a and the state of Maine and federal offi- JOINT TRIB. COUN. OF PASSAMAQUODDY TRIBE V. MORTON 371 Cite as F.2d 370 (1975) of that cials appealed. The Court of Appeals, maquoddy Tribe did not-cut off whatev- buse of Levin H. Campbell, Circuit Judge, held federal duties existed. 25 U.S.C.A. of vol- that the Nonintercourse Act applies to $ 177; 22 M.R.S.A. § 4831 the Passamaquoddy Tribe and estab- 5. Indians 7 Serv- lished a trust relationship between the and United States and the tribe. No con- Unwillingness of Congress to furnish gressional termination of the guardian- aid when requested by Passamaquoddy ship role was shown, and neither the Indian Tribe did not alone show congres- tribe nor the state of Maine would have sional intention that Nonintercourse Act the right to terminate the federal should not apply. 25 U.S.C.A. § 177. government's responsibility. 6. Indians 10 Judgment ffirmed. Under Nonintercourse Act, federal government bears trust relationship to Passamaquoddy Indian Tribe; such rela- 1. Indians 10 tionship under the Act pertains to land Right to extinguish Indian title is "transactions which are or may be cover- the attribute of sovereignty which no state, ed by the Act and is rooted in rights and a., but only United States, can exercise, and duties encompassed or created by the Nonintercourse Act gives statutory rec- Act. 25 U.S.C.A. § 177. ognition to that fact. 25 U.S.C.A. § 177; Act Mar. 1, 1793, 1 Stat. 137, 329; Act 7. Indians 6 Mar. 3, 1819, 3 Stat. 516; Act Mar. 3, Once Congress has established trust F 1820, 3 Stat. 544. relationship with an Indian tribe, Con- gress alone has right to determine when 2. Indians -2 pellant. its guardianship shall cease; neither the Passamaquoddy Tribe of Indians, tribe nor state of Maine, separately or the though not otherwise federally recog- together, has right to make that decision F nized, is "tribe" within Nonintercourse and so to terminate the federal govern- Act. 25 U.S.C.A. § 177. ment's responsibilities. 25 U.S.C.A. See publication Words and Phrases § 177; 22 M.R.S.A. § 4831. for other judicial constructions and definitions. retary, 8. Indians -6 al., 3. Indians 6 Any withdrawal of trust obligations Congress' power to regulate com- toward Indian tribe by Congress would merce includes-authority to decide when have to be plain and unambiguous to be and to what extent it shall recognize effective. 25 U.S.C.A. § 177. particular Indian community as depend- ent tribe under its guardianship, and 9. Indians -6 Congress has right to determine for it- Record in Indian tribe's action self when guardianship maintained over against Secretary of the Department of Indian shall cease, but Congress' power the Interior and other defendants failed is limited in sense that it may. not bring to establish that Congress had at any community or body of people within time terminated or withdrawn its protec- he joint range of its power by arbitrarily calling tion which had been extended under the In- them an Indian tribe, and may exercise Nonintercourse Act. 25 U.S.C.A. § 177. governors its guardianship and protection only in claratory respect of distinctly Indian communities. 10. Courts 365(1) of the 25 U.S.C.A. § 177; U.S.C.A.Const. art. 1, Federal government had no obliga- the tribe. § 8. tion to respond to decision by the Su- a party preme Judicial Court of Maine, which for the 4. Indians =7 could not affect federal authority with District Voluntary assistance rendered by respect to Indian tribe, and federal Edward state to Indian tribe is not necessarily government's alleged failure to react to 649, inconsistent with federal protection, and such decision was not to be taken by a offi- Maine's assumption of duties to Passa- federal district court as an acknowledg- 372 528 FEDERAL REPORTER, 2d SERIES ment of such state court ruling. 25 U.S. State of Maine on behalf of the Tribe. C.A. § 177. Earlier, in a letter to the Commissioner of the Bureau of Indian Affairs, the Tribe had stated the following griev- Martin L Wilk, Deputy Atty. Gen., ances against Maine and its predecessor, with whom Joseph E. Brennan, Atty. Massachusetts (hereinafter collectively Gen., was on brief, for State of Maine, "Maine"): that Maine "had divested the Augusta, Me., appellant. Tribe of most of its aboriginal territory Edmund B. Clark, Atty., Dept. of Jus- in a treaty negotiated in 1794; that tice, with whom Wallace H. Johnson, Maine had wrongfully diverted 6,000 of Asst. Atty. Gen., Walter Kiechel, Deputy the 23,000 acres reserved to the Tribe in Asst. Atty. Gen., and Edward J. Shawak- that treaty; and that Maine had mis- er, Atty., Dept. of Justice, Washington, managed tribal trust funds, interfered D. C., for Rogers C. B. Morton, appel- with tribal self-government, denied trib- lants. al hunting, fishing and trapping rights, Thomas N. Tureen, Calais, Me., with and taken away the right of members to whom David C. Crosby, Barry A. Margo- vote, from 1924 to 1967. The Tribe had lin, Calais, Me., Stuart P. Ross, Hogan & requested the Secretary to sue Maine on Hartson, Washington, D. C., Robert S. its behalf to redress these asserted Pelcyger, Boulder, Colo., and Robert E. wrongs before July 18, 1972, the date an Mittel, Portland, Me., were on brief for action would allegedly be barred.¹ Al- appellees. though the Commissioner of the Bureau of Indian Affairs favored compliance Before COFFIN, Chief Judge, McEN- with plaintiffs' request, defendants did TEE and CAMPBELL, Circuit Judges. not act. LEVIN H. CAMPBELL, Circuit On June 2, 1972, plaintiffs filed this Judge. action, seeking a declaratory judgment This is an appeal from a declaratory that the Tribe is entitled to federal pro- judgment entered in the District Court tection under the Indian Nonintercourse for the District of Maine. 388 F.Supp. Act, 25 U.S.C. § 177,2 and a preliminary 649, 667 (D.Me.1975). injunction. ordering defendants to file a Plaintiffs are, under Maine law, the protective action on the Tribe's behalf political representatives of the Passa- against the State of Maine by July 18, maquoddy Indian Tribe ("the Tribe"). 1972. Defendants persisted in their re- 22 M.R.S.A. § 4831 (Supp.1975). They fusal to sue for the Tribe, relying upon brought this action against the Secretary the advice of the Acting Solicitor for the of the Interior and the Attorney General Department of the Interior, who stated, of the United States after the Secretary "[N]o treaty exists between the United refused to initiate a lawsuit against the States and the Tribe and, except for 1. 28 U.S.C. § 2415(b) sets forth a special stat- authority of the United States, attempts to ne- ute of limitations for actions seeking damages gotiate such treaty or convention, directly or resulting from trespass on Indian lands. The indirectly, or to treat with any such nation or time for filing such an action was originally tribe of Indians for the title or purchase of any July 18, 1972, but has since been extended by lands by them held or claimed, is liable to a Congress to July 18, 1977. Act of October 13, penalty of $1,000. The agent of any State who 1972, P.L. 92-485, 86 Stat. 803. may be present at any treaty held with Indians 2. Title 25 U.S.C. § 177 provides as follows: under the authority of the United States, in the presence and with the approbation of the com- "No purchase, grant, lease, or other convey- missioner of the United States appointed to ance of lands, or of any title or claim thereto, hold the same, may, however, propose to, and from any Indian nation or tribe of Indians, adjust with, the Indians the compensation to shall be of any validity in law or equity, unless be made for their claim to lands within such the same be made by treaty or convention State, which shall be extinguished by treaty." entered into pursuant to the Constitution. Ev- ery person who, not being employed under the JOINT TRIB. COUN. OF PASSAMAQUODDY TRIBE V. MORTON 373 Cite as 528 F.2d (1975) isolated and inexplicable instances in firm, subject to the qualifications herein- the past, this Department, in its trust after stated. capacity, has had no dealings with the Tribe. On the contrary, it is the I States of Maine and Massachusetts which have acted as trustees for the The issues in this proceeding can best tribal property for almost 200 years. be understood in light of facts about the Tribe appearing in the parties' stipula- tion and exhibits and in the district court's comprehensive and scholarly opin- [W]e are aware that the ion.4 Tribe may thus be foreclosed from The Tribe now resides on two reserva- pursuing its claims against the State in the federal courts. However, as tions in Washington County in Maine. there is no trust relationship between Its members and their ancestors, as was agreed below, have constituted an Indian the United States and this Tribe, tribe in both the racial and cultural, the Tribe's proper legal rem- sense since at least 1776. Plaintiffs al- edy should be sought elsewhere." lege that until 1794 the Tribe occupied After a hearing, the district court or- its aboriginal territory all of what is dered defendants to file suit by July 1, now Washington County and certain oth- 1972, and to include all matters of which er land in Maine. In 1777, the Tribe the Tribe had complained. In compli- pledged its support to the American Col- ance, they instituted United States V. onies during the Revolutionary War in Maine, Civil No. 1966 N.D. An appeal exchange for promises by John Allan, from that order was dismissed on mo- Indian agent of the Continental Con- tions of both plaintiffs and defendants. gress, that the Tribe would be given am- Civil No. 1966 N.D. has meanwhile been munition for hunting, protection for stayed pending final determination of their game and hunting grounds, regula- the present action. tion of trade to prevent imposition, the Plaintiffs then filed two amended and exclusive right to hunt beaver, the free supplemental complaints herein, aban- exercise of religion, and a clergyman. doning their request for an injunction In addition, an agent would be appointed and seeking only a declaratory judg- for their protection and support in time ment. The State of Maine was allowed of need. Allan, as Superintendent of the to intervene. As finally framed and ar- Eastern Indian Agency, reported to the gued in the district court, the issues federal government on several occasions were,³ (1) whether the Nonintercourse in 1783 and 1784 that the Passamaquod- Act applies to the Passamaquoddy Tribe; dy Tribe had greatly assisted the revolu- (2) whether the Act establishes a trust tionary cause and urged Congress to ful- relationship between the United States fill these promises made on the Govern- and the Tribe; and (3) whether the ment's behalf. Allan also transmitted United States may deny plaintiffs' re- the views of the Tribe in this regard. quest for litigation on the sole ground However, the Continental Congress that there is no trust relationship: The failed to act on Allan's recommendations. district court ruled in plaintiffs' favor on His appointment was revoked in March all points. Both the federal defendants 1784, under a resolution revoking the ap- and the State of Maine appeal. We af- pointments of all Indian Superintend- 3. Plaintiffs also requested in their second 4. Plaintiffs' contentions that the Department amended and supplemental complaint a declar- of the Interior has wrongfully turned its back atory judgment that the Const. art. I, §§ 8 on the Tribe, and that federal guardianship and 10, and art. II, § 2, are applicable to the must replace that of the State, are elaborated Tribe. Relief along these lines was not pur- in detail in O'Toole & Tureen, State Power and sued below and is not now an issue. the Passamaquoddy Tribe; "A Gross National Hypocrisy?", 23 Me.L.Rev. 1 (1971). 374 528 FEDERAL REPORTER, 2d SERIES ents. In 1790, the First Congress adopt- this Commonwealth [Massachusetts], to- ed the Indian Nonintercourse Act. wards the Indians within said District of Maine, whether the same arise from In 1792, the Passamaquoddy Tribe pe- treaties, or otherwise Maine titioned Massachusetts for land upon was thereafter recognized by Congress which to settle, and Massachusetts ap- and admitted to the Union. Act of pointed a committee to investigate, one March 3, 1820, ch. 19, 3 Stat. 544. The member of which was the same John Maine Constitution, with the above quot- Allan. Allan reported that during the ed provision relating to the Indians, was Revolutionary War the Passamaquoddy read in the Senate, referred to commit- Tribe had given up its -claims to lands tee, and finally declared by Congress to known to be its haunts on the condition be established in the course of the ad- that the United States would confirm its mission proceedings. "ancient spots of ground" and a suitable tract for the use of both the Tribe and Since its admission as a state, Maine all other Indians who might resort there. has enacted approximately 350 laws Soon after, in 1794, Massachusetts en- which relate specifically to the Passama- tered into an agreement, also referred to quoddy Tribe. This legislation includes as a treaty, with the Passamaquoddy 72 laws providing appropriations for or Tribe by which the Tribe relinquished all regulating Passamaquoddy agriculture; its rights, title, interest, claims or de- 33 laws making provision for the appro- mands of any lands within Massachu- priation of necessities, such as blankets, setts in exchange for a 23,000 acre tract food, fuel, and wood, for the Tribe; 85 comprising Township No. 2 in the first laws relating to educational services and range, other smaller tracts, including ten facilities for the Tribe; 13 laws making acres at Pleasant-point, and the privilege provision for the delivery of health care of fishing on both branches of the services and facilities to the Tribe; 22 Schoodic River. All pine trees fit for laws making allowance for Passama- masts were reserved to the state govern- quoddy housing; 54 laws making special ment for a reasonable compensation. An provision for Indian indigent relief; 54 additional ninety acres at Pleasant-point laws relating to the improvement and were later appropriated to the use of the protection of roads and water on the Tribe by Massachusetts in 1801. Passamaquoddy reservation; and 15 laws providing for the legal representation of Since 1789, Massachusetts and later the Tribe and its members. Maine have assumed considerable respon- In contrast, the federal government's sibility for the Tribe's protection and dealings with the Tribe have been few. welfare. Maine was a District of Massa- It has never, since 1789, entered into a chusetts until 1819, when it separated treaty with the Tribe, nor has Congress from Massachusetts under the Articles of ever enacted any legislation mentioning Separation, Act of June 19, 1819, Mass. the Tribe. In 1824, the Department of Laws, ch. 61, p. 248, which were incorpo- War contributed funds to the Tribe, one- rated into the Maine Constitution as Ar- third toward the construction of a school, ticle X, Section 5. The Articles provided pursuant to an act for the civilization of that Maine "shall assume and Indian tribes. Act of March 3, 1819, 3 perform all the duties and obligations of Stat. 516. It also gave money annually 5. The first Nonintercourse Act, 1 Stat. 137, chase or grant of lands, or of any title or claim 138, provided that "no sale of lands made by thereto, from any Indians or nation or tribe of any Indians, or any nation or tribe of Indians Indians, within the bounds of the United within the United States, shall be valid to any States, shall be of any validity in law. or equi- person or persons, or to any state ty, unless the same be made by a treaty or unless the same shall be made and duly exe- convention entered into pursuant to the consti- cuted at some public treaty, held under the tution." Subsequent amendments have made authority of the United States." This was no major changes and the present version was amended in 1793, 1 Stat. 329, 330: "No pur- enacted in 1834. (See note 2 supra.) JOINT TRIB. COUN. OF PASSAMAQUODDY TRIBE V. MORTON 375 Cite as 528 F.2d 370 (1975) from 1824 to 1828 under the same act to ment of Housing and Urban Develop- Elijah Kellogg of the Society for the ment, writing to the Commissioner of Propagation of the Gospel Among the the Maine Department of Indian Affairs Indians, to support a school for the in regard to the establishment of public Tribe. The funds were granted at the housing authorities by the governing request of the State of Maine, were councils of the Passamaquoddy and Pe- channeled through the State, and were nobscot Tribes, stated in part that "[i]t is subject to State controls. Kellogg, ac- our understanding that these tribes do cording to one nineteenth century not have any governmental powers in source, was himself sent to the Tribe as their own right or by virtue of any fed- a schoolmaster by the State of Maine, eral law. and as a missionary by the Missionary In 1968, the Tribe brought suit against Society of Massachusetts. These funds the Commonwealth of Massachusetts in were withheld during 1829 because of the Massachusetts state courts alleging intra-tribal differences concerning the that the Commonwealth, with the con- religion of the Superintendent of the sent of the federal government, assumed school and, as a result, two principal men jurisdiction over and responsibility for of the Tribe, Deacon Sockbason and Sa- the Tribe and that by the act admitting battis Neptune, went to Washington to Maine into the Union, Congress con- meet with Thomas L McKenney, Di- firmed and ratified that relationship. rector of the Office of Indian Affairs, and John H. Eaton, Secretary of War, to II seek reinstatement of the school funds and additional money to hire a priest The central issue in this action is and to purchase a parcel of land. Money whether the Secretary of the Interior was again appropriated for the school was correct in finding that the United and the priest in 1830, although discon- States has no trust, relationship" with tinued after 1831 on account of the same the Tribe and, therefore, should play no intra-tribal differences. However, de- role in the Tribe's dispute with Maine. spite a request from President Jackson, Whether, even if there is a trust rela- Congress failed to appropriate any mon- tionship with the Passamaquoddies, the ey to purchase land for the Tribe. After United States has an affirmative duty to the school funds were again suspended sue Maine on the Tribe's behalf is a sep- during 1831 because of the same sectari- arate issue that was not raised or decid- an strife, the Tribe requested that the ed below and which consequently we do funding be reinstated and used for the not address. The district court held only improvement of the Tribe's agriculture; that defendants "erred in denying plain- this request was also denied and the tiffs' request for litigation on the sole funding was never resumed. During the ground that no trust relationship exists period from 1899 to 1912, five members between the United States and the Pas- of the Tribe attended the Carlisle Indian samaquoddy Tribe." It was left to the School for short periods of time. A Secretary to translate the finding of a member of the Tribe also graduated "trust relationship" into concrete duties. from Haskel Indian College in 1970. Over the years, the federal govern- Since 1965, various federal agencies oth- ment has recognized many Indian tribes, er than the Department of the Interior specifically naming them in treaties, have provided funds to the Tribe under agreements, or statutes. The general federal assistance programs available to notion of a "trust relationship," often all citizens meeting the requirements of called a guardian-ward relationship, has the program. Some of these funds were been used to characterize the resulting taken from special Indian allocations or relationship between the federal govern- were administered by special Indian ment and those tribes, see Worcester V. desks within the various agencies. In Georgia, 31 U.S. (6 Pet.) 515, 8 L.Ed. 483 1966, the General Counsel to the Depart- (1832); Cherokee Nation V. Georgia, 30 376 528 FEDERAL REPORTER, 2d SERIES U.S. (5 Pet.) 8 L.Ed. 25 (1831); and ment's protective role under the Nonin- the cases cited in the district court's tercourse Act, see below, it is appropri- opinion, 388 F.Supp. at 662-63. It is the ate that plaintiffs and the federal defendants' and the intervenor's conten- government learn how they stand on tion here that such a relationship may these core matters before adjudication of only be claimed by those specifically rec- the Tribe's dispute with Maine ognized Yet the resulting bifurcation of deci- The Tribe, however, contends other- necessarily restricts the reach of the wise. It rests its claim of a trust rela- present rulings. In reviewing the dis- tionship on the Nonintercourse Act, en- trict court's decision that the Tribe is a acted in its original form by the First tribe within the Nonintercourse Act, we Congress in 1790 to protect the lands are not to be deemed as settling, by im- of "any tribe of Indians." plication or otherwise, whether the Act Plaintiffs argue, and the district court affords relief from, or even extends to, found, that the unlimited reference to the Tribe's land transactions with Maine. "any tribe" must be read to When and if the specific transactions are include the Passamaquoddy Tribe as well litigated, new facts and legal and equita- as tribes specially recognized under sepa- ble considerations may well appear, and rate federal treaties, agreements or stat Maine should be free in-any such future utes. As the Act applies to them, plain- litigation to defend broadly, even to the tiffs urge that it is sufficient to evidence extent of arguing positions and theories congressional acknowledgement of a which overlap considerably those treated trust relationship in their case at least as here respects the Tribe's land claims. Now, however, for purposes of the is- Before turning to the district court's sues currently existing between them- rulings, we must acknowledge a certain selves and the federal government, plain- awkwardness s in deciding whether the tiffs are entitled to declaratory rulings Act encompasses the Tribe without con- on the basis of which courses can be sidering at the same time whether the charted and actions planned and taken. Act encompasses the controverted land transactions with Maine. Whether the Is the Passamaquoddy Tribe a "tribe" within the Nonintercourse Tribe is a tribe within the Act would best be decided, under ordinary circum- stances, along with the Tribe's specific [1] The district court found the Pas- land claims, for the Act only speaks of samaquoddy Tribe to be within the lan- tribes in the context of their land deal- guage of the Nonintercourse Act, "any ings. If that approach were adopted tribe of Indians." It read the here, however, the Tribe would be de- quoted language as encompassing all prived of a decision in time to do any tribes of Indians. The court reasoned good on those matters cited by the that the Act should be given its plain Department of the Interior as reasons meaning, there being no evidence of any for withholding assistance in litigation contrary congressional intent, legislative against Maine. And without United history, or administrative interpretation; States participation, the Tribe may find that the policy of the United States is to it difficult or impossible ever to secure a protect Indian title; that there is no judicial determination of the claims. reason why the Passamaquoddy Tribe Given, in addition, the federal govern- should be excluded since it is stipulated 6. Indian title, also called "right of occupancy," extinguish Indian title is an attribute of sover- refers to the Indian tribes' aboriginal title to eignty which no state, but only the United land which predates the establishment of the States, can exercise, the Nonintercourse Act United States. See, e. g., Oneida Indian Na- giving statutory recognition to that fact. Id. at tion V. County of Oneida, 414 U.S. 661, 667, 94 667, 670, 94 S.Ct. 772; O'Toole & Tureen, su- S.Ct. 772, 39 L.Ed.2d 73 (1974). The right to pra note 4, at 25-26. JOINT TRIB. COUN. OF PASSAMAQUODDY TRIBE V. MORTON 377 the Nonin- to be a tribe racially and culturally; that with appellants' interpretation. Rather is appropri- there is no requirement that tribe we find an inclusive reading consonant the federal must be otherwise recognized by the fed- with the policy and purpose of the Act stand on eral government to come within the That policy has been said to be to pro- djudication of Nonintercourse Act; and that even if tect the Indian tribes' right of occupan- Maine. "tribe" is thought to be ambiguous, it cy, even when that right is unrecognized of deci- should be construed non-technically and by any treaty, United States V. Santa Fe reach of the to the advantage of Indians so as to Pacific R. Co., 314 U.S. 339, 345, 347, 62 the dis- include the Passamaquoddy Tribe S.Ct. 248, 86 L.Ed. 260 (1941), rehearing the Tribe is a [2, 3] Intervenor and defendants con- denied, 314 U.S. 716, 62 S.Ct. 476, 86 course Act, we tend that "any tribe of Indi- L.Ed. 570 (1942), and the purpose to pre- ettling, by im- ans" is ambiguous; that its proper vent the unfair, improvident, or improp- ether the Act meaning is a community of Indians er disposition of Indian lands, Federal extends to, Power Commission V. Tuscarora Indian which the federal government has at with Maine. some time specifically recognized; and Nation, 362 U.S. 99, 119, 80 S.Ct. 543, 4 ransactions are that the Passamaquoddy Tribe is, in that L.Ed.2d 584, rehearing denied, 362 U.S. and equita- sense, not a tribe. "No court", says in- 956, 80 S.Ct. 858, 4 L.Ed.2d 873 (1960); appear, and tervenor, "has ever held a statute regu- United States V. Candelaria, 271 U.S. such future lating trade and intercourse with Indians 432, 441, 46 S.Ct. 561, 70 L.Ed. 1023 even to the to apply to a tribe which the Federal (1926). Since Indian lands have, histori- and theories Government disavows any relationship cally, been of great concern to Congress, those treated with. see Oneida Indian Nation V. County of Oneida, 414 U.S. 661, 667, 94 S.Ct. 772, But while Congress' power to regulate of the is- 39 L.Ed.2d 73 (1974), we have no diffi- commerce with the Indian tribes, U.S. between them- culty in concluding that Congress intend- Const. art. I, § 8, includes authority to ernment, plain- ed to exercise its power fully. decide when and to what extent it shall aratory rulings recognize a particular Indian community This is not to say that if there were courses can be as a dependent tribe under its guardian- doubt about the tribal status of the and taken. ship,⁷ United States Sandoval, 231 Tribe, the judgments of officials in the Tribe a U.S. 28, 46, 34 S.Ct. 1, '58 L.Ed. 107 federal executive branch might not be of Nonintercourse (1913), Congress is not prevented from great significance. The Supreme Court legislating as to tribes generally; and has said that, it is the rule of this court this appears to be what it has done in to follow the executive and other politi- found the Pas- successive versions of the Nonintercourse cal departments of the government, within the lan- Act. There is nothing in the Act to sug- whose more special duty is to deter- Act, "any gest that "tribe" is to be read to exclude mine such affairs." United States V. It read the a bona fide tribe not otherwise federally Sandoval, 231 U.S. at 47, 34 S.Ct. at 6, compassing all recognized.⁸ Nor, as the district court quoting United States V. Holliday, 70 court reasoned found, is there evidence of congressional U.S. (3 Wall.) 407, 419, 18 L.Ed. 182 given its plain intent or legislative history squaring (1865). But the Passamaquoddies were a evidence of any legislative 7. Congress also has right to determine for there is no question that the Tribe is a "dis- interpretation; itself when the guardianship which has been tinctly Indian" community. States is to maintained over the Indian shall cease. Unit- 8. In United States V. Candelaria, 271 U.S. 432, there is no ed States V. Sandoval, 231 U.S. 28, 46, 34 S.Ct. 442, 46 S.Ct. 561, 563, 70 L.Ed. 1023 (1926), naquoddy Tribe 1, 6, 58 L.Ed. 107 (1913). On the other hand, the Supreme Court, quoting Montoya V: United it is stipulated Congress' power is limited in the sense that it States, 180 U.S. 261, 266, 21 S.Ct. 358, 45 may not bring "a community or body of peo- L.Ed. 521 (1901), read "Indian tribe," as used ple within the range of [its] power in the Nonintercourse Act of 1834, 25 U.S.C. attribute of sover- by arbitrarily calling them an Indian tribe," $ 177, to mean "a body of Indians of the same only the United and may exercise its guardianship and protec- or a similar race, united in a community under lonintercourse Act tion only "in respect of distinctly Indian com- one leadership or government, and inhabiting to that fact. Id. at munities." Id. It having been stipulated, a particular, though sometimes ill-defined, ter- oole & Tureen, su- however, that the Passamaquoddy Tribe is a ritory." The Tribe plainly fits that definition. tribe in both the racial and cultural sense, 528 F.2d-24½ 378 528 FEDERAL REPORTER, 2d SERIES tribe before the nation's founding and do, it is true, suggest that the Act's cov- have to this day been dealt with as a erage is limited to. tribes consisting of tribal unit by the State.' See 22 M.R. "simple, uninformed an inter- S.A. ch. 1355. No one in this proceeding pretation understandable in light of the has challenged the Tribe's identity as a Act's protective purpose. But it is not tribe in the ordinary sense. Moreover, claimed that the Tribe and its members there is no evidence that the absence of are so sophisticated or assimilated as to federal dealings was or is based on be other than those entitled to protec- doubts as to the genuineness of the Pas- tion. Cf. Joseph, supra. Candelaria is samaquoddies' tribal status, apart, that cited mainly in support of intervenor's is, from the simple lack of recognition. argument that the Act requires federal Under such circumstances, the absence recognition, but it does not elevate rec- of specific federal recognition in and of ognition to a sine qua non it merely itself provides little basis for concluding indicates that if there is a question of that the Passamaquoddies are not a inclusion, federal recognition of depend- "tribe" within the Act. ent, tribal status may be helpful evi- Intervenor cites two cases dealing dence of Gongress' intent. with the Pueblo Indians of New Mexico for its contention that "tribe" refers only [4,5] Appellants also assert that to tribes that have been federally recog- there is significance to Congress' approv- nized. United States V. Candelaria, su- al of the Articles of Separation between pra; United States V. Joseph, 94 U.S. Maine and Massachusetts, providing that 614, 24 L.Ed. 295 (1876). In Joseph, the Maine would assume the duties and obli- Supreme Court found that the Pueblo gations which Massachusetts owed to the Indians were not a tribe within the Non- Indians. But, as the district court recog- intercourse Act, apparently because of nized, Maine's assumption of duties to their high degree of civilization and the the Tribe did not cut off whatever feder- nature of their earlier relations with the al duties existed. Voluntary assistance Government of Mexico when they had rendered by a state to a tribe is not been under its control.¹ In Candelaria, necessarily inconsistent with federal pro- the Court held that the Pueblos did come tection. See State V. Dibble, 62 U.S. (21 within the Act, though it did not ex- How.) 366, 16 L.Ed. 149 (1858). Similar- pressly overrule the Joseph view that ly, Congress' unwillingness to furnish aid some tribes, because highly civilized or when requested did not, without more, otherwise, might conceivably be exempt. show a congressional intention that the The Court found that the Pueblos were a Nonintercourse Act should not apply. simple, uninformed people such as the (See Part II, C infra.) The reasons be- Act was intended to protect and pointed hind Congress' inaction are too proble- to federal recognition in the past as evi- matic for the matter to have meaning dencing Congress' intention to protect for purposes of statutory construction. the Pueblos. 271 U.S. at 440-42, 46 Cf. Order of Railway Conductors V. S.Ct. 561. These cases lend little aid to Swan, 329 U.S. 520, 529, 67 S.Ct. 405, 91 intervenor and defendants. The cases L.Ed. 471 (1947). 9. In State V. Newell, 84 Me. 465, 24 A. 943 tribal existence for purposes of the Act turns (1892), it is true, the Maine court disputed the on whether a given tribe has retained sover- continued viability of the Tribe, apparently on eignty in this absolute sense. the grounds that its sovereignty, such as the 10. The Pueblos had submitted to all laws of power to make war or peace, and the like, had the Mexican Government, their civil rights had vanished, and the political and civil rights of its members were enforced only in the courts been fully recognized, and they had been ab- of the State. Nonetheless that court did ac- sorbed into the "general mass of the popula- tion." United States V. Joseph, 94 U.S. 614, knowledge the Passamaquoddies' tribal organi- 617, 24 L.Ed. 295 (1876). zation for certain purposes, id. at 468, 24 A. 943, and no federal cases hold that the test of JOINT TRIB. COUN. OF PASSAMAQUODDY TRIBE V. MORTON 379 Cite as 528 2d 370 (1975) that the Act's cov- We have considered appellants's re- We emphasize what is obvious, that tribes consisting of maining arguments carefully and find the "trust relationship" we affirm has as -people," an inter- them unpersuasive. We agree with the its source the Nonintercourse Act, mean- able in light of the district court that the words any ing that the trust relationship pertains ose But it is not tribe of Indians" appearing in the Act to land transactions which are or may be be and its members include the Passamaquoddy Tribe. covered by the Act, and is rooted in or assimilated as to rights and duties encompassed or created entitled to protec- B. Is there 2 trust relationship between by the Act. Congress or the executive pra Candelaria is the Passamaquoddy. Tribe and the branch may at a later time recognize the ort of intervenor's federal government? Tribe for other purposes within their ict requires federal powers, creating a broader set of federal es not elevate rec- [6] The district court found that the responsibilities; and we of course do not ua non it merely Nonintercourse Act establishes a trust rule out the possibility that there are re is a question of relationship between the United States statutes or legal theories not now before ognition of depend- and the Indian tribes, including the Pas- us which might create duties and rights ay be helpful evi- samaquoddy Tribe. It relied on a series of unforeseen, broader dimension. But itent. of decisions by the Court of Claims, Fort on the present record, only the Noninter- Sill Apache Tribe V. United States, 201 course Act is the source of the finding of also assert that Ct.Cl. 630, 477 F.2d 1360 (1973); United "trust relationship," and neither the to Congress' approv- States Oneida Nation of New York, decision below nor our own is to be read Separation between 201 Ct.Cl. 546, 477 F.2d 939 (1973); Sen- as requiring the Department of the Inte- setts, providing that eca Nation V. United States, 173 Ct.CL rior to look to objects outside the Act in the duties and obli- 917 (1965), while also finding support in defining its fiduciary obligations to the chusetts owed to the an extensive body of cases holding that Tribe. district court recog- when the federal government enters into Once this is said, there is little else aption of duties to a treaty with an Indian tribe or enacts a left, since it would be inappropriate to off whatever feder- statute on its behalf, the Government attempt to spell out what duties are im- Voluntary assistance commits itself to a guardian-ward rela- posed by the trust relationship. This dis- to a tribe is not tionship with that tribe. See, e. g., pute arises merely from the defendants' nt with federal pro- Heckman V. United States, 224 U.S. 413, flat denial of any trust relationship; no Dibble, 62 U.S. (21 32 S.Ct. 424, 56 L.Ed. 820 (1912); United question of spelling out specific duties is 149 (1858). Similar- States V. Kagama, 118 U.S. 375, 6 S.Ct. presented. It is now appropriate that gness to furnish aid 1109, 30 L.Ed. 228 (1886); Worcester V. the departments of the federal govern- not, without more, Georgia, supra. ment charged with responsibility in these intention that the We agree with the district court's con- matters should be allowed initially at should not apply. clusions and in large part with its rea- least to give specific content to the de- L) The reasons be- soning and analysis of legal authority. clared fiduciary role. ion are too proble- That the Nonintercourse Act imposes Thus we are not moved by intervenor's r to have meaning upon the federal government a fiduci- criticism of the lower court's interpreta- utory-construction ary's role with respect to protection of tion of cited Court of Claims cases, for Conductors the lands of a tribe covered by the Act those arguments go more to the scope of 529, S.Ct. 405, 91 seems to us beyond question, both from the federal government's duties under the history, wording and structure of the particular circumstances than to the ex- Act and from the cases cited above and istence of a trust relationship. Nor are poses of the Act turns in the district court's opinion. The pur- we moved by intervenor's other com- be has retained sover- pose of the Act has been held to ac- plaint that the judgment below implies sense. knowledge and guarantee the Indian some sort of overly "general" fiduciary bmitted to all laws of tribes' right of occupancy, United States relationship, unlimited and undefined. It, their civil rights had V. Santa Fe Pacific R. Co., 314 U.S. at and they had been ab- A fiduciary relationship in this context il mass of the popula- 348, 62 S.Ct. 248, and clearly there can must indeed be based upon a specific Joseph, 94 U.S. 614, be no meaningful guarantee without a statute, treaty or agreement which helps i). corresponding federal duty to investigate define and, in some cases, limit the rele- and take such action as may be warrant- vant duties; but, as we have held, the ed in the circumstances. Nonintercourse Act is such a statute. 380 528 FEDERAL REPORTER, 2d SERIES We affirm, on the basis set forth here- ter V. Shaw, 280 U.S. 363, 367, 50 S.Ct. in, the finding of a trust relationship and 121, 74 L.Ed. 478 (1930). We agree with the finding that the federal government the district court that any-withdrawal of may not decline to litigate on the sole trust obligations by Congress would have ground that there is no trust relation- to have been "plain and unambiguous" ship. to be effective.¹ We also agree that there is no affirmative evidence that C. Are plaintiffs precluded by acquies- Congress at any time terminated or cence or by congressional termina- withdrew its protection under the Nonin- tion of its guardianship role from tercourse Act. The federal government now asserting a trust relationship has been largely inactive in relation to with the federal government? the Tribe and has, on occasion, refused [7] Intervenor also contends that, un- requests by the Tribe for assistance. In- der general equitable principles, the tervenor argues that this course of deal- Tribe should be precluded from now in- ings is sufficient in and of itself to show voking a trust relationship with the fed- a withdrawal of protection. However, eral government because of its long- refusing specific. requests is quite differ- standing relationship with the State of ent from broadly refusing ever to deal Maine. However, once Congress has es- with the Tribe, and, as stated above, tablished a trust relationship with an In- there is no evidence of the latter. dian tribe, Congress alone has the right to determine when its guardianship shall [10] Intervenor also points to a deci- cease. United States V. Nice, 241 U.S. sion by the Supreme Judicial Court of 591, 598, 36 S.Ct. 696, 60 L.Ed. 1192 Maine, State V. Newell, 84 Me. 465, 24 A. (1916); Tiger V. Western Investment Co., 943 (1892), which found that the Passa- 221 U.S. 286, 315, 31 S.Ct. 578, 55 L.Ed. maquoddy Tribe has never been recog- 738 (1911). Neither the Passamaquoddy nized by the fedeal government, and ar- Tribe nor the State of Maine, separately gues that the federal government's fail- or together, would have the right to ure to react to that decision by recogniz- make that decision and so terminate the ing the Tribe in some way amounts to an federal government's responsibilities.¹¹ acknowledgement of that ruling. How- [8, 9] We turn, then, to whether Con- ever, the federal government had no ob- gress itself has manifested at any time a ligation to respond to the state court's determination that its responsibilities un- decision, which could not affect federal der the Nonintercourse Act should cease authority with respect to the Tribe. See with respect to the Tribe. The district Oneida Indian Nation V. County of Onei- court cited a rule of construction that da, supra. statutes or treaties relating to the Indi- We accordingly affirm the district ans shall be construed liberally and in a court's ruling that the United States non-technical sense, as the Indians would never sufficiently manifested withdrawal naturally understand them, and never to of its protection so as to sever any trust the Indians' prejudice. Antoine V. relationship. In so ruling, we do not Washington, 420 U.S. 194, 199-200, 95 foreclose later consideration of whether S.Ct. 944, 43 L.Ed.2d 129 (1975); Carpen- Congress or the Tribe should be deemed 11. One might argue that, although Congress 12. The Supreme Court has said with respect to has not terminated this relationship, the the termination of Indian reservations that it Tribe's own course of dealings with the State will not lightly conclude that a reservation has of Maine still prevent it from asking Congress been terminated and will require a clear indi- for assistance. However, the Indians' pre- cation of that fact. DeCoteau V. District sumed helplessness is at the heart of the County Court, 420 U.S. 425, 444, 95 S.Ct. guardian-ward analogy; to deny the ward a 1082, 43 L.Ed.2d 300 (1975). right to call upon the guardian for protection would be to deny that he was incapable of looking out for himself. UNITED STATES V. WILLIS 381 Cite as 528 F.2d 381 (1976) in some manner to have acquiesced in, or of the drawer was forged, and where he Congress to have cratified, the Tribe's drew the money after the forged check of land transactions with Maine. cleared the Texas bank, he was properly Judgment affirmed.. found guilty of interstate transportation of a forged security, even though the fruition of the alleged scheme occurred after the mails were utilized. 18 U.S. o KEY NUMBER SYSTEM C.A. § 2314. 2. Receiving Stolen Goods 1 Mail fraud statute's peculiar lan- to guage, i.e., that use of the mails be for the purpose of executing a fraudulent UNITED STATES of America, scheme, is not an element of the crime Plaintiff-Appellee, of interstate transportation of a forged V. security; all that the interstate transpor- tation statute requires is that defendant Alvin WILLIS, Jr., either transport or cause to be transport- Defendant-Appellant. ed in interstate commerce the forged se- No. 75-3009. curity knowing it was forged. 18 U.S. C.A. $ 2314. United States Court of Appeals, Ninth Circuit. of Jan. 12, 1976. Jerome S. Stanley, Sacramento, Cal., for defendant-appellant. Bruce Babcock, Jr., Asst. U. S. Atty., The United States District Court for Sacramento, Cal., for plaintiff-appellee. the Eastern District of California, Thom- as J. MacBride, Chief Judge, found de- OPINION fendant guilty of interstate transporta- Before CHOY and KENNEDY, Circuit tion of a forged security, and he appeal- Judges, and WONG,* District Judge. ed. The Court of Appeals held that where defendant knowingly and fraudu- PER CURIAM: lently deposited a forged check drawn on On stipulated facts, Defendant was a Texas bank in his California bank ee found guilty of interstate transportation account knowing that the signature of of a forged security. We affirm. the drawer was forged, and where he He contends here that United States drew the money after the forged check V. Maze, 414 U.S. 395, 94 S.Ct. 645, 38 cleared the Texas bank, he was properly L.Ed.2d 603 (1974) bars his conviction be- found guilty of interstate transportation cause the fruition of the alleged scheme of a forged security, even though the occurred after the mails were utilized. fruition of the alleged scheme. occurred after the mails were utilized. (In Maze, a case under the mail fraud statute, 18 U.S.C. § 1341, the mailing Affirmed. occurred after the fraud was consum- mated so the Court held that the use of to 1. Receiving Stolen Goods -1 the mails had not been "for the purpose it Where defendant' knowingly and of executing such [fraudulent] scheme or fraudulently deposited a forged check artifice" as the statute required.) drawn on a Texas bank in his California [1] Here the essential stipulated facts Ct. bank account knowing that the signature were that Willis knowingly and fraudu- The Honorable Dick Yin Wong, United States District Judge, District of Hawaii, sitting by designation. THE WHITE HOUSE WASHINGTON August 26, 1976 MEMORANDUM FOR: The Secretary of the Treasury The Secretary of Defense The Attorney General The Secretary of the Interior The Secretary of Agriculture The Secretary of Commerce The Secretary of Labor The Secretary of Health, Education, and Welfare The Secretary of Housing and Urban Development The Secretary of Transportation The Director, Office of Management and Budget The Chairman, Civil Service Commission The Administrator of General Services The Administrator, Small Business Administration The Administrator of Veterans Affairs The Director, Community Services Administration The Administrator, Environmental Protection Agency The Acting Chairman, Equal Employment Opportunity Commission The Governor, Farm Credit Administration I am today designating Bradley H. Patterson, Jr., of the White House Office to assist me in the area of American Indian affairs. It will be Mr. Patterson's specific responsibility to work with each of you to improve the coordination among the Federal agencies with programs that serve the Indian people. It is important that you insure the effective delivery and efficient operation of Federal Indian programs and services. I request that priority attention be given to coordination of these efforts among the Departments and Agencies and within the Executive Office of the President. In addition, I request you continue to insure that when Federal actions are planned which affect Indian communities, the responsible Indian leaders are consulted in the planning process. FORD LIBRARY Some items in this folder were not digitized because it contains copyrighted materials. Please contact the Gerald R. Ford Presidential Library for access to these materials. Welcome To INDIAN ISLAND Home of the Penobso The New York Times/Arthur Grace Nicholas Sappiel, leader of Penobscot Indians, chides Maine officials who "used to laugh about this case" Maine Indian Suit for Land Halts Bond Sales and Endangers Titles By JOHN KIFNER Special to The New York Times CALAIS, Me., Oct. 23-The Indians may But Mr. Tureen, a young antipoverty legally own two-thirds of Maine. lawyer who read the fine print of history, This possibility, raised in a lawsuit that has steered his case over a convoluted seemed insignificant, even ludicrous, four course that saw the Federal courts order years ago, has suddenly blocked the sale the United States Government to sue the of millions of dollars of municipal bonds, State of Maine on behalf of the Indians. cast in doubt the ownership of private Mr. Tureen contends that the Federal lands and whole towns and thrown the courts have now settled what he says is state government here into consternation. the central issue of the case by finding The suit on behalf of the Passamaquod- that the Nonintercourse, Act applies to dy and Penobscot Indian tribes charges the Maine tribes. that their ancestrial forest lands were il- "Nobody could believe it," Mr. Tureen legally bargained away to the local white said of the suit he filed in 1972, and authorities in violation of the Federal added, "We would have settled cheap." Nonintercourse Act of 1790. The claims center on 12 million acres Now the Indians, who were allies of or more, worth some $25 billion, accord- the patriots in the Revolution, are not ing to Thomas N. Tureen, alttorney for the inclined to accept Gov. James B. Longley's Indians here. urging that they drop their land claims. "They used to laugh about this case The existence of the case has, in recent and everything else," said Nicholas Sappi- days, stopped the sale of $27 million of el, the leader of the Penobscot Indians. bonds by the Maine Bond Bank, halting "Now they're getting a few gray hairs. school and hospital construction in small You've never seen: so many lawyers. It municipalities. It has also left the larger reminds you of a cartoon." towns of Ellsworth and Millinocket un- "It's preposterous," said State Attorney able to float $4.4 million in bonds and General Joseph E. Brennan, Maine's chief sent Governor Longley and other offi- legal officer. You just don't undo 200 years of history that readily Continued on Page 59, Column 1 THE WHITE HOUSE WASHINGTON November 24, 1976 MEMORANDUM FOR: JIM CONNOR BOBBIE KILBERG BK FROM: Counsel's Office agrees with the actions reported in Cannon's memorandum. CC: Phil Buchen FORD GERALO THE WHITE HOUSE ACTION MEMORANDUM WASHINGTON LOG NO.: Date: November 18, 1976 Time: FOR ACTION: CC (for information): Phil Buchen (Bobbie Kilberg) FROM THE STAFF SECRETARY DUE: Date: Soon as Possible Time: SUBJECT: Memo from Bradley Patterson & George Humphreys re: Governor Longley's Inquirey re the Passamaquoddy/Penobscot Case ACTION REQUESTED: For Necessary Action For Your Recommendations Prepare Agenda and Brief Draft Reply X For Your Comments Draft Remarks REMARKS: As Discussed would like your comments on this informational memo before sending into the President. GERALD LIBRARY A. FORD PLEASE ATTACH THIS COPY TO MATERIAL SUBMITTED. If you have any questions or if you anticipate a Jim Connor delay in submitting the required material, please For the President telephone the Staff Secretary immediately. THE WHITE HOUSE WASHINGTON INFORMATION November 15, 1976 MEMORANDUM FOR THE PRESIDENT THROUGH: JAMES M. CANNON BRADLEY H. PATTERSON, July JR. Pred Patterm FROM: GEORGE W. HUMPHREYS SUBJECT: Governor Longley's Inquiry re the Passamaquoddy/Penobscot Case Governor Longley of Maine met with you recently and asked you to look into this matter; you told him you would do so. The Passamaquoddy Indian Tribal Council won a Federal Court decision from Judge Gignoux at the beginning of 1975 declaring that the United States has a trust responsibility to the Tribe and declaring that the Tribe is in fact covered by the terms of the 1790 Nonintercourse Act (25 USC 177) which forbids the conveyance of Indian land without the consent of the United States. This decision was affirmed by the First Circuit Court of Appeals on December 23, 1975. The chain of effects from that decision is: -- The land conveyances in the treaties of 1794 and 1818 between Maine (then Massachusetts) and the Passamaquoddy and Penobscot Indians respectively, wherein the Indians gave up some 2,000,000 and 10,000,000 acres respectively of their aboriginal lands may well be void, since the United States was not a party to these treaties nor were they ever ratified by the Senate. -- This in turn puts a cloud over the ownerships and titles in those 12,000,000 acres -- which amounts to 60% of the State of Maine. FORD is LIBRARY -2- - Because of this cloud, bond attorneys have advised clients not to buy State of Maine construction bonds, and a $27 million sale of same has been held up. -- Tax anticipation bonds (from real estate taxes) for the operating expenses of Maine towns and counties will probably suffer the same fate as of next January. This will hurt some of those communities. -- The Federal Government, now as Trustee for the Indians, has in the Circuit Court's words "the duty to investigate and take such action as may be warranted in the circumstances." This may well mean pursuing or expanding (to other property-owning defendants) two protective lawsuits filed some time ago against Maine on behalf of the tribes by Justice at the insistence of the Court. - Judge Gignoux has set back a November 15 deadline to January 15, 1977 for the Federal Government to come into his court and tell him what they are going to do to discharge their trusteeship obligation. Much research must be done to put any expanded suits in final form before a July, 1977 expiration of the Statute of Limitations for all Indian claims for trespass damages. The State Attorney General continues to call the Indians' claim "preposterous", "frivolous" and "without merit"; the Maine Congressional delegation introduced a bill to repeal the Nonintercourse Act and has more recently washed its hands of the matter claiming that it is a problem for the Courts. The Indians have long been ready to talk about a comprehensive settlement package but the State has shown little interest. Actions Now Being Taken: Solicitor Austin of Interior is sending a letter to the Maine Deputy General, transmitting documents showing the the strength of the case and inviting his input and comment. WWW.LIBRARY is 078870 -3- Secretary Kleppe is responding to a letter he has received from Governor Longley, will refer to Mr. Austin's invitation to the State Deputy Attorney General, and will also refer to the Governor's visit with you - - by saying that "The President has asked me to look into this matter." We and Mr. Buchen believe that this discharges your obligation to Governor Longley and keeps the matter at the proper arm's length from the White House. The Future: After receiving input from both the Indians and the State, Interior will send its Litigation Report to Justice --- i.e., the formal request for definitive or expanded lawsuits. The Litigation Report will then be made available to the Indians and the State and further comments will be invited. These comments may point to a possible overall settlement, such as a "Maine Native Claims Settlement Act" by the Congress (as an alternative to months if not years of claims litigation.) Justice will inform Judge Gignoux of the steps taken so far. Mr. Carter, then as President, will have to make the final judgment about what kind of lawsuits or a legislative package to support. GERALD FORD LIBRARY THE WHITE HOUSE WASHINGTON November 29, 1976 NOTE FOR Phil Buchen George Numphreys Attached for your information are copies of the two letters which Interior has sent to Maine officials, i.e. Governor Longley and Deputy Attorney General Paterson respectively. As agreed, the letter to the Governor mentions the President's interest in this matter. Interior will send me a copy of the material received from Mr. Paterson when it arrives. Bad FORD LIBRARY DEPARTMENT OF United States Department of the Interior OFFICE OF THE SECRETARY March OFF WASHINGTON, D.C. 20240 Honorable James B. Longley State of Maine Office of the Governor NOV 22 1976 Augusta, Maine 04333 Dear Governor Longley: Thank you for your letters of October 8 and October 26, 1976, regarding the land claims of the Maine Indian Tribes. As I indicated to you when we met some weeks ago, I understand and appreciate the very real concerns of the people of your State. The President has also expressed interest in this matter, and has asked me to give it my personal attention. As you know, shortly after our meeting Mr. Brennan, your Attorney General, met with Mr. Austin, my chief legal officer. Subsequent to that meeting, attorneys in the Solicitor's Office, including Mr. Austin himself, under- took a very careful analysis of a proposed litigation report to the Justice Department with regard to the claims of the Passamaquoddy Tribe. A similar report on the claims of the Penobscot Nation is in the preliminary stages. That analysis is not yet completed. It involves, among many other things, a complete historical and legal review of over 200 years of transactions. It is not proper to suggest that our ultimate decision in this matter is controlled by a threat of a suit by the Tribe. This Department was sued by one of the tribes and this Depart- ment defended that suit jointly with the State of Maine. The Court has now rendered its decision and we are required to comply with that judgment. I am understandably concerned with the implications contained in your stated desire that you receive "fair treatment or fairer treatment" than you perceive you have received to date. I was unaware of any unevenness of treatment in this respect but I will restate the position I enunciated at the time of our conversation REVOLUTION AMERICAN BICENTENNIAL 1776-1976 DERALO FORD LIBRARY -2- in my office: the posture of the Government today vis-a-vis the State of Maine is different from the relationship that existed when the Government and the State defended the suit of the tribe in the Joint Tribal Council of the Passamaquoddy Tribe V. Morton. Nothing in the foregoing is to be taken as meaning that we are not keenly aware of the ramifications of the situation. You were particularly effective in bringing home to me the seriousness of the State's position and the distress some persons in your State have already experienced. We are not unconcerned. For example, Mr. Austin has indicated to me that he appreciates your Deputy Attorney General's letter of October 21, 1976 in which he offers to submit a memorandum on his view of the Indian claims. Mr. Austin also informs me that he is amenable to the idea of sharing with your Attorney General certain of the materials which support the Passamaquoddy and Penobscot land claims so that the Department's litigation reports will reflect a thoroughly considered decision in these matters. This is but one indication of our desire to try to assist the State all we can subject to the legal limitations placed on us by our trust relationship with the Tribes. Please be assured that we are giving high priority to the evaluation of the tribal claims and that that evaluation will be the result of very careful study. Sincerely yours, H. Gray Quitin Acting Secretary of the Interior FORD is LIBRARY 071439 DEPARTMENT OF United States Department of the Interior THE OFFICE OF THE SOLICITOR WASHINGTON, D.C. 20240 NOV 11 1976 John M. R. Paterson, Esquire Deputy Attorney General Department of the Attorney General State of Maine Augusta, Maine 04333 Dear Mr. Paterson: This will acknowledge your letter of October 21, 1976, with respect to United States V. Maine, in which you stated your understanding of the status of the preparation of our litigation report to the Department of Justice, requested that the United States make available to you certain factual and historical materials which we now have in hand, and described your reservations concerning the disclosure to the United States of factual and legal aspects of the position of the State of Maine in opposition to the anticipated claims of the Passamaquoddy and Penobscot Tribes. While your description of our present posture is accurate, the matter is of sufficient importance that I would like to restate one point in order to avoid even a remote possibility of misunderstanding. The draft litigation report submitted by us to the Department of Justice does take the form of a firm recommendation; however, you are correct in stating that we have not yet made a firm recommendation to the Department, since our report is still in draft form. We are thoroughly sympathetic with the concerns expressed by you with respect to revealing, at this time, the factual or legal basis of your position in opposition to the anticipated claims of the Passamaquoddy and Penobscot Tribes. I would like to repeat that we have neither requested nor urged that the State make such a disclosure to us. However, I did state that we are still in the process of formulating the position which this Department will take on behalf of 8 GERALD FORD LIBRARY -2- the Tribes, and that any factual or legal information supplied to us by the State of Maine might be helpful to us in establishing our position and deciding upon the course which we will pursue on behalf of the Indian Tribes. In response to your request that we make factual and historical materials available to you, we are submit- ting herewith summaries of the factual bases for the Passamaquoddy and Penobscot land claims. If you wish to attempt to rebut any or all of the conclusions found therein, please 'do so in the memorandum which you intend to prepare for us. Again, however, please understand that you are not obliged to do so. I think we agree that it is in everyone's interest to resolve the questions posed by the Tribes' claims as soon as possible. Therefore, if you expect to offer your arguments to us, please submit them no later than November 30, 1976. As you know, the Justice Department is now required to inform the court of the government's final decision by January 15, 1977. Sincerely yours, Solicitor H. Gregory Austin Entended to Dec. 7 at Patersois's request. R. FORDA LIBRA THE WHITE HOUSE washington November 23 TO: PHIL BUCHEN FROM: GEORGE W. HUMPHREYS Memo went to the President on 11/15. FURD LIBRARY COPY FOR MR. BUCHEN THE WHITE HOUSE WASHINGTON copy Hold FILE. November 12, 1976 v MEMORANDUM FOR THE PRESIDENT THROUGH: JAMES M. CANNON FROM: BRADLEY H. PATTERSON, JR. GEORGE W. HUMPHREYS SUBJECT: Governor Longley's Inquiry re the Passamaquoddy/Penobscot Case Governor Longley of Maine met with you recently and asked you to look into this matter; you told him you would do so. The Passamaquoddy Indian Tribal Council won a Federal Court decision from Judge Gignoux at the beginning of 1975 declaring that the United States has a trust responsibility to the Tribe and declaring that the Tribe is in fact covered by the terms of the 1790 Nonintercourse Act (25 USC 177) which forbids the conveyance of Indian land without the consent of the United States. This decision was affirmed by the First Circuit Court of Appeals on December 23, 1975. The chain of effects from that decision is: The land conveyances in the treaties of 1794 and 1818 between Maine (then Massachusetts) and the Passamaquoddy and Penobscot Indians respectively, wherein the Indians gave up GERALD FORD LIBRAFT some 2,000,000 and 10,000,000 acres respectively of their aboriginal lands may well be void, since the United States was not a party to these treaties nor were they ever ratified by the Senate. --This in turn puts a cloud over the ownerships and titles in those 12,000,000 acres -- which amounts to 60% of the State of Maine. - 2 - --Because of this cloud, bond attorneys have advised clients not to buy State of Maine construction bonds, and a $27 million sale of same has been held up. Tax anticipation bonds (from real estate taxes) for the operating expenses of Maine towns and counties will probably suffer the same fate as of next January. This will hurt some of those communities. The Federal Government, now as Trustee for the Indians, has in the Circuit Court's words "the duty to investigate and take such action as may be warranted in the circumstances." This may well mean pursuing or expanding (to other property-owning defendants) two protective lawsuits filed some tine ago against Maine on behalf of the tribes by Justice at the insistence of-the Court. --Judge Gignoux has set back a November 15 deadline to January 15, 1977 for the Federal Government to come into his court and tell him what they are going to do to discharge their trusteeship obligation. Much research must be done to put any expanded suits in final form before a July, 1977 expiration of the Statute of Limitations for all Indian claims for trespass damages. The State Attorney General continues to call the Indians' claim "preposterous,' "frivolous" and "without merit"; the Maine Congressional delegation introduced a bill to repeal the Nonintercourse Act and has more recently washed its hands of the matter claiming that it is a problem for the Courts. The Indians have long been ready to talk about a comprehensive settlement package but the State has shown little interest. Actions Now Being Taken: Solicitor Austin of Interior is sending a letter to the Maine Deputy Attorney General, transmitting documents showing the strength of the case and inviting his input and comment. - 3 - Secretary Kleppe is responding to a letter he has received from Governor Longley, will refer to Mr. Austin's invitation to the State Deputy Attorney General, and will also refer to the Governor's visit with you -- by saying that "The President has asked me to look into this matter.' We and Mr. Buchen believe that this discharges your obligation to Governor Longley and keeps the matter at the proper arm's length from the White House. The Future: After receiving input from both the Indians and the State, Interior will send its Litigation Report to Justice -- i.e., the formal request for definitive or expanded lawsuits. The Litigation Report will then be made available to the Indians and the State and further comments will be invited. These comments may point to a possible overall settlement, such as a "Maine Native Claims Settlement Act" by the Congress (as an alternative to months if not years of claims litigation.) Justice will inform Judge Gignoux of the steps taken so far. Mr. Carter, then as President, will have to make the final judgment about what kind of lawsuits or a legislative package to support. FORD is 074870 LIBRARY Indian THE WHITE HOUSE WASHINGTON December 3, 1976 MEMORANDUM TO: PHIL BUCHEN BRADLEY PATTERSON FROM: JIM CANNON SUBJECT: Passamaquoddy Jui and Penobscot Land Claims The President would like an option paper for his review on the Maine Indian land claims problem. I have asked George Humphreys to work with you, or your designate, to present a full discussion of possible Presidential action that may be advisable in order to effect an early settlement. George will be calling you shortly for your advice and guidance. As a starter, I am attaching five legislative options that have been suggested to us. You may want to review this list for any good ideas it may suggest. FORD : 038470 LIBRARY PASSAMAQUODDY SETTLEMENT LEGISLATION OPTIONS Option 1: The President could recommend that the Congress ratify the 1794 Treaty conveyance nunc pro tunc, thus probably extinguishing any claim which the tribes may have to the land in question or compensation therefor. Option 2: The President could recommend to the Congress the enactment of a Maine Native Claims Settlement Act (MNCSA) which would provide that the Indian Claims Commission, or a specially constituted commission, would determine the scope of the aboriginal lands of the tribes as of 1794, and determine the value of the aboriginal lands which were conveyed by the tribes under the 1794 Treaty, and then award to the tribes the 1794 value of the aboriginal lands which were conveyed, which would probably amount to something less than $15 million. In addition, the Indians could be awarded interest on the value of the lands conveyed. At 5% per annum simple interest, this would increase the award by a factor of approximately 10, to a total of something less than $150 million. At 5% per annum compound interest, the increase would be by a factor of approximately 700, to a total of something less than $105 billion. Option 3: The President could recommend a MNCSA which would provide that the Indian Claims Commission, or a similarly constituted commission, would evaluate the legal claim now being advanced by the Indians, and award to the tribes the present value of any land the title to which the tribes were found to have a valid claim. This award would amount to the present value of up to 16 million acres of Maine land including approximately 100,000 private homes and buildings. Option 4: The President could recommend a MNCSA which would simply set an arbitrary sum to be paid to the tribes in full settlement of any legal claims they might have by reason of the 1794 Treaty. Such a settlement might amount to a pay- ment of cash in the amount of $1,000 to $100,000 for each of the approximately 3,000 members of the tribes. Option 5: The President could recommend a MNCSA along the lines described in options 2 through 4 and, in addition, recommend that the MNCSA contain provisions requiring that the State of Maine, as its contribution to the settlement, deed certain state-owned lands to the tribes. FORD : LIBRARY GERALD 2 DISCUSSION Option 1: The Congress has legal authority to extinguish Indian land claims, such as are involved in these cases, by statute without compensation. It can be argued that the Maine Indians have no equitable or moral argument in support of their claim, and that any compensation paid to them would amount to a windfall. The tribes have not argued that they were dealt with unjustly, but rather based their entire claim solely upon technical non-compliance with the Nonintercourse Act. Option 2: Historically, Congress has not taken a hard line on extinguishment of aboriginal title. Under the Indian Claims Act, Congress has *provided that tribes who have lost their aboriginal lands unfairly under Federal treaties may sue for the value of the land at the time of loss. Although the Indian Claims Act generally provides for compensation when there is a presence of fraud, unconscionable considera- tion, etc., an analogy could be made between such situations and the extinguishment of a valid claim under the Nonintercourse Act. No interest is allowed under the Indian Claims Act but if simple reimbursement for the 1794 value of the land (probably less than $1 per acre) appears unreasonably low, simple interest might be added for these purposes. Option 3: As a matter of Indian advocacy, this option must be considered. This option would give to the Indians the monetary equivalent of the value of the tribes' Nonintercourse Act Claim. To give the tribes anything less is, arguably, to take from the tribes something granted by act of Congress. Option 4: This option could be supportable on grounds that, in light of the availability of option 1, only token compen- sation is justifiable. It would have the further advantages of being fast, simple and predictable in cost. Option 5: Since fault, if any, lies with the State of Maine (or its predecessor, the State of Massachusetts), and since the entire burden of the Indian claim will fall on the residents of the State of Maine in the absence of congressional action, there is good justification for requiring a contribution from the State of Maine to the settlement. The State of Maine does own undeveloped lands which could be made available to the tribes. Since the tribes claim close attachment to the land, providing land as a part of the compensation might make a settlement more palatable to the tribes. FORD LIBRARY is DIVY