People of Saipan v. United States Department of Interior

The United States and the Trust Territory of the Pacific Islands (Trust Territory) (also known as Micronesia) entered into a treaty known as the Trusteeship Agreement in which the United States agreed to promote the economic advancement and self-sufficiency of the inhabitants of the Trust Territory and to regulate the use of the Trust Territory’s natural resources. In 1970, Continental Airlines applied to the government of the Trust Territory for permission to build a hotel adjacent to historical beaches on the island of Saipan. In 1972, against the advice of the applicable advisory board, the high commissioner of the Trust Territory, appointed at the federal level, executed a lease permitting Continental to build the hotel. The United States Department of the Interior (defendant) supported the high commissioner’s decision. After unsuccessfully seeking an injunction with the high court of the Trust Territory, the people of the Trust Territory filed an action in the United States District Court for the District of Hawaii, arguing violations of the National Environmental Policy Act of 1969 (NEPA) and that the Trusteeship Agreement guaranteed rights to the people that were enforceable in the court. The district court held that NEPA applies to federal agencies operating in the Trust Territory but that no federal action occurred. Further, the district court held that the Trusteeship Agreement did not create rights assertable in federal court. Thus, the district court dismissed the action. The people of the Trust Territory appealed. On appeal, the Department of the Interior argued that a treaty like the Trusteeship Agreement may only be argued in international court.