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United States v. Mitchell

United States Supreme Court
463 U.S. 206 (1983)


In 1887, the United States government (defendant) allotted land to Mitchell and other individual Indians (plaintiffs) under the General Allotment Act (GAA), 25 U.S.C. § 331 et seq. Much of this land could not be inhabited, but contained valuable timber. Over time, the secretary of the interior (defendant) began to manage the foresting of timber from these allotments for the Indians. The Act of June 25, 1910 (Act), 25 U.S.C. §§ 406-07, authorized the secretary of the interior to sell timber on behalf of the Indians and provide the Indians with the proceeds. The Department of Indian Affairs also created guidelines and regulations to govern this process. However, the Indians gradually became aware that the process was not being managed properly and was not serving their best interests. Consequently, the plaintiffs sued the United States for a breach of trust duties. The court of claims held that the Act imposed a fiduciary duty on the United States. The United States Supreme Court reversed this decision and remanded the case to the court of claims, finding that the Act did not create a fiduciary relationship between the Indians and the United States. On remand, the court of claims held that the United States was liable for a breach of trust. The Supreme Court granted certiorari.

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