United States v. Mazurie

Martin and Margaret Mazurie (defendants) were non-Indians who owned the Blue Bull bar (the bar) on fee-patent land within the Wind River Reservation in Wyoming. Until 1971, the Wind River tribe (the tribe) allowed retail liquor sales on reservation land, and the Mazuries held a state liquor license. In 1971, pursuant to a federal statute delegating regulation of alcohol to tribal authorities, the tribe passed a new ordinance requiring both tribal and state liquor licenses for retail liquor sales. The Mazuries applied for a tribal liquor license and were denied, but they continued to operate the bar nonetheless. The Mazuries were subsequently convicted in district court for introducing alcoholic beverages into Indian country in violation of federal law. The district court held that Congress had the power to reach non-Indians located on privately held land within a reservation. The court of appeals reversed, holding that, even if Congress had such power, it could not delegate that power to the tribe. The court of appeals reasoned that, because the tribe was a private and voluntary organization comprised of US citizens, the tribe could not exercise governmental authority or sovereignty over other citizens, like the Mazuries, who did not and could not participate in matters regarding tribe organization, and therefore, Congress could not delegate its authority to such an organization. The United States Supreme Court granted certiorari.