Santa Clara Pueblo v. Martinez

Santa Clara Pueblo Indian law required that the children of a female member of the tribe be full-blooded Santa Clara Pueblo Indian to become a member of the Santa Clara Pueblo Indian Tribe (Tribe) (defendant). The offspring of male members of the Tribe were not similarly restricted from joining the Tribe. Martinez (plaintiff), a female member of the Santa Clara Pueblo Indian Nation, had two children who were half Navajo. Martinez’s children were denied Santa Clara Pueblo membership, including the right to vote and to hold leadership positions. Martinez sued the Tribe in the United States District Court for the District of New Mexico. Martinez argued that the membership rule discriminated on the basis of sex and ancestry and violated the Indian Civil Rights Act of 1968 (ICRA), 25 U.S.C. §§ 1301–03. The district court upheld the membership rule as central to the Tribe’s culture and economy and as valid under the ICRA. This holding implied that Martinez had a right to bring an ICRA claim in federal, rather than in tribal court. Martinez appealed, and the United States Court of Appeals for the Tenth Circuit reversed. The tenth circuit also recognized a federal cause of action under the ICRA, but held that the Tribe had not shown a compelling interest to justify a membership rule that discriminated on the basis of sex. The United States Supreme Court granted certiorari to determine whether Martinez was permitted to bring a civil lawsuit in federal court under the ICRA