Cobell v. Norton

The federal government held land in trust accounts for the Indians under the Indian Reorganization Act of 1934, 25 U.S.C. § 461 et seq. These trust accounts were known as Individual Indian Money (IIM) accounts. Cobell was one of group of Indians (Indians) (plaintiffs) who sued the Secretary of the Interior and federal employees (government) (defendants) for a full accounting of the IIM accounts held by the government. The Indians believed that money within the accounts was being mismanaged. The district court held that the Indians were entitled to an accounting of the IIM accounts under both the government’s general fiduciary duty to the Indians and the fiduciary duties imposed on the government by the Indian Trust Fund Management Reform Act (Reform Act), 25 U.S.C. § 4001 et seq. The district court ordered the government to provide an accounting to the Indians. The government appealed, arguing that the Reform Act did not require the government to provide an accounting to IIM account holders. Because an accounting was outside the scope of the government’s fiduciary duties, the government claimed that the district court was not authorized to grant equitable relief in the form of an accounting to the Indians. The government further argued that the government’s interpretation of the Reform Act should be given deference under Chevron U.S.A., Inc. v. Natural Resources Defense Council, Inc., 467 U.S. 837 (1984). Chevron requires that an agency interpretation of a statute be given deference unless arbitrary or capricious.