Salazar v. Ramah Navajo Chapter

The Indian Self-Determination and Education Assistance Act (ISDA) instructs the Secretary of the Interior (the secretary) (defendant) to enter contracts with Indian tribes in order for the federal government (defendant) to cover all the costs of services, such as education, that would otherwise be provided by the government. The ISDA notes that the contracts are made subject to the availability of appropriations. The Ramah Navajo Indians and other Indian tribes (the tribes) (plaintiffs) entered ISDA contracts with the government. During the relevant years that the contracts were in effect, Congress appropriated funds sufficient to cover the contract support costs incurred by any individual tribal contractor but not enough to cover the support costs for all tribal contractors in the aggregate. Therefore, the secretary paid each contractor only a portion of the contract support costs. The tribes sued for breach of contract in federal district court, claiming the government had failed to pay their support costs in full, as was required by the ISDA. The district court granted summary judgment for the secretary. The Tenth Circuit reversed, holding that, because Congress had allocated enough funds to pay all support costs for any individual tribal contractor, thus making those funds legally available, the secretary and government were bound by the contractual commitment to pay all support costs for all tribal contractors. The United States Supreme Court granted certiorari.