State of Idaho v. Hodel

The Coeur d’Alene Indian Reservation was established by executive order in 1873. The Allotment Act of 1906 provided 160 acres of reservation land to each tribe member and opened up the unallotted land for homesteading. However, in the Act of 1908, Congress withdrew a portion of the reservation, and the United States secretary of the interior conveyed the land to the state of Idaho (plaintiff) for use as a public park. In 1911 the land was formally conveyed to Idaho under a land patent that required title to revert to the United States if any portion was not used as a public park. At the time of the land patent, cottage leasing was prevalent in multiple state parks, as well as national parks, and in 1920 Idaho began issuing permits for float homes and leases for waterfront cottages within the park. In the 1950s, the federal government began working to eliminate leaseholds on public lands. On March 3, 1976, the United States Department of the Interior informed the Idaho attorney general that the permit-and-leasing practice was out of compliance with the 1911 conveyance. On December 30, 1976, Idaho filed suit in federal district court against Donald Hodel (defendant), in his capacity as secretary of the interior, and sought a declaratory judgment that permits and leases did not violate the public-park provision within the land patent. The federal district court granted Idaho’s motion for summary judgment. The Coeur d'Alene Tribe appealed the grant of summary judgment to the Ninth Circuit, contending that Idaho had violated the terms of the 1911 land patent.