Yellen v. Confederated Tribes of the Chehalis Reservation

594 U.S. ___ (2021)

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Yellen v. Confederated Tribes of the Chehalis Reservation

United States Supreme Court
594 U.S. ___ (2021)

  • Written by Liz Nakamura, JD

Facts

In 1971, Congress enacted the Alaska Native Claims Settlement Act (ANCSA), which created the Alaska Native Corporations (ANCs) (defendants). ANCs are village and regional private corporations that manage and hold title to millions of acres of Alaskan land on behalf of their shareholders, all of whom are Alaska Natives. In 1975, the Indian Self-Determination and Education Assistance Act (ISDA) was enacted, which, in relevant part, defined the term “Indian tribe” to include (1) all Indian tribes, nations, or communities, and (2) all ANCs established under ANCSA that were recognized as eligible for special federal programs benefitting Indians. In 2020, to address the economic devastation caused by the coronavirus pandemic, Congress passed the $2.2 trillion Coronavirus Aid, Relief, and Economic Security Act (CARES). Under CARES, $8 billion in federal aid was reserved for tribal governments. CARES defined “tribal government” to mean the governing body of any Indian tribe as defined by ISDA. The Treasury Department (defendant), under Secretary Janet Yellen (defendant), set aside $450 million for ANCs. The Confederated Tribes of the Chehalis Reservation (Confederated Tribes) (plaintiffs) sued, arguing that ANCs were ineligible for CARES aid because ANCs did not meet ISDA’s eligibility requirements for classification as Indian tribes. Specifically, the Confederated Tribes argued that ANCs could not be classified as Indian tribes under ISDA because the ANCs were private, for-profit corporations that were not recognized as eligible for special federal programs benefitting Indian tribes. The district court granted summary judgment to the Treasury Department and the ANCs. On appeal, the District of Columbia Circuit reversed, holding that ANCs did not qualify as Indian tribes under ISDA and were therefore ineligible to receive CARES funds intended for tribal governments. The United States Supreme Court granted certiorari.

Rule of Law

Issue

Holding and Reasoning (Sotomayor, J.)

Dissent (Gorsuch, J.)

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