Cayuga Indian Nation v. Pataki

413 F.3d 266 (2005)

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Cayuga Indian Nation v. Pataki

United States Court of Appeals for the Second Circuit
413 F.3d 266 (2005)

LJ

Facts

The Cayuga Indian Nation (Cayuga Nation) (plaintiff) owned and occupied approximately 3,000,000 acres of tribal land located in the area currently known as the State of New York. In 1789 the Cayuga Nation entered into a treaty with the State of New York ceding all of its land to the state, less 64,015 acres. In 1790 Congress passed the Indian Trade and Intercourse Act (the act), which prohibited the sale of tribal land without first obtaining the approval of the federal government. In 1795 the Cayuga Nation entered into another treaty with the State of New York, ceding 64,012 of the remaining acres of tribal land in consideration of an annual payment of $1,800 to the Cayuga Nation in perpetuity. In 1807 the State of New York acquired the remaining three acres of tribal land from the Cayuga Nation. However, the federal government never ratified the 1795 or the 1807 treaties authorizing the transfer of tribal land as required by the act. In 1980 the Cayuga Nation filed a complaint against George Pataki (defendant), the governor of the State of New York, seeking a declaration that the Cayuga Nation was the legal owner of, and held equitable title and the right of possession to, the 64,015 acres of tribal land conveyed by the 1795 and 1807 treaties. As relief, the Cayuga Nation asserted trespass, requested that the court return possession of the land to the Cayuga Nation and eject any party claiming chain of title through the 1795 and 1807 treaties. Pataki asserted that the Cayuga Nation had abandoned the land and that its claims were barred by laches. The United States District Court for the Northern District of New York held that the 1795 and 1807 treaties conveying the tribal land were not properly ratified by the federal government, were in violation of the act, and were therefore invalid. The court rejected Pataki’s claims of abandonment and laches. Eight years after its decision on liability, the district court held that ejectment was not appropriate and that monetary damages should be granted. On the issue of damages, a jury awarded approximately $247,912,000 to the Cayuga Nation. Pataki filed an appeal.

Rule of Law

Issue

Holding and Reasoning (Cabranes, J.)

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