## Facts

- The Cayuga Nation historically occupied a large territory in central New York, including reservation lands.
- In 1795 and 1807, New York State obtained agreements conveying approximately 64,015 acres of Cayuga reservation land without federal ratification.
- The Cayuga Indian Nation of New York and the Seneca-Cayuga Tribe of Oklahoma, joined by the United States, alleged the conveyances violated the Nonintercourse Act, 25 U.S.C. § 177, which bars alienation of tribal lands without federal consent.
- Litigation began in 1980; the district court certified a landowner defendant class and rejected defenses including laches.
- The district court ruled the conveyances invalid under § 177 and found defendants liable for unlawful possession.
- The district court denied ejectment but awarded money damages: roughly $36.9 million for current fair market value plus rental value, and about $211 million in prejudgment interest, totaling about $247.9 million.
- Defendants appealed; the tribal plaintiffs cross-appealed on remedial issues.
- While the appeal was pending, the Supreme Court decided City of Sherrill v. Oneida Indian Nation, addressing equitable limits on long-delayed tribal land-related claims.

## Issues

1. Whether laches and related equitable doctrines (including acquiescence and impossibility) bar the plaintiffs’ centuries-old possessory land claim under federal law after City of Sherrill.
2. Whether any laches-based bar applies to the United States as plaintiff-intervenor seeking relief on the same claim.
3. Whether a large money judgment measured by present-day land value and long-term use can stand if the underlying claim is barred as inequitable and disruptive.

## Decision

- The Second Circuit reversed the district court’s judgment and directed entry of judgment for defendants.
- The court held the plaintiffs asserted a “possessory land claim” and that, under Sherrill’s equitable framework, laches and related doctrines barred the claim.
- The court held the bar applied not only to ejectment-type relief but also to the monetary award, treated as the functional equivalent of restoring possessory rights.
- The court applied the equitable bar to the United States as well as the tribal plaintiffs because the federal intervenor sought the same possessory-based relief.
- A dissent argued Sherrill was inapplicable to a damages claim for historic dispossession under § 177 and that laches should not run against the United States.

## Legal Principles

- A centuries-old tribal claim seeking to vindicate present possessory rights to land (or relief effectively substituting for possession) may be barred by laches and related equitable doctrines when enforcement would be highly disruptive to settled expectations and governance.
- Under Sherrill, equitable bars may apply even if the underlying land transaction violated federal law and even absent a controlling statute of limitations.
- A court may treat a large damages award measured by present-day land value and extensive historical use as functionally equivalent to ejectment or trespass relief for purposes of equitable analysis.
- In this context, the equitable bar can extend to the United States when it participates in and seeks relief on the same long-delayed, disruptive possessory claim.

## Conclusion

The Second Circuit set aside a substantial monetary judgment and held that, after long delay and extensive changes in ownership and governance, equitable doctrines bar disruptive, possessory tribal land claims and comparable substitute money remedies, applying that bar to both tribal plaintiffs and the United States.


Cayuga Indian Nation of N.Y. v. Pataki, 413 F.3d 266 (2d Cir. 2005)