Sangre De Cristo Development Company, Inc. v. United States

Sangre De Cristo Development Company, Inc. (Sangre) (plaintiff) sought to develop a golf course on lands held by the Tesuque Indian Pueblo (the tribe) in New Mexico. The United States Department of Interior approved a lease between Sangre and the tribe. However, a coalition of neighboring landowners and environmental groups brought suit against the United States (defendant) to enjoin further approvals in relation to the lease until an environmental-impact statement (EIS) could be conducted. For the next few years, Sangre worked with the United States Bureau of Indian Affairs, the Council on Environmental Quality, and other entities to prepare the EIS. The tribe, after a change in leadership, reversed its position on the lease, asking the Department of the Interior to rescind it. In response to this request, and in consideration of environmental factors, the Interior Department rescinded the lease. Sangre entered involuntary bankruptcy proceedings. The trustee of Sangre’s estate then brought suit against the United States government in federal district court on behalf of the estate, seeking damages for alleged harm caused by the government’s cancellation of the lease. More specifically, Sangre argued that it had a vested property interest in the lease, entitling it to compensation under the Takings Clause of the Fifth Amendment to the United States Constitution. The court rejected Sangre’s Takings Clause argument and found in favor of the United States. Sangre appealed to the United States Court of Appeals for the Tenth Circuit.