## Facts

- Individual Indian Money (IIM) accounts are trust accounts holding funds for individual Native American beneficiaries, largely derived from income generated by allotted Indian lands and related resource uses.
- A certified class of IIM beneficiaries sued federal officials responsible for trust administration, including the Secretary of the Interior and the Secretary of the Treasury, in their official capacities.
- Plaintiffs alleged long-running failures to account for, manage, and report IIM trust funds, including incomplete records and inadequate accounting systems and controls.
- After extensive proceedings, the district court held a bench trial focused on declaratory and injunctive relief defining and enforcing the government’s trust-management and accounting obligations.
- The district court found ongoing, material breaches of fiduciary duties and ordered agency action to repair trust administration, including an accounting and court-supervised reporting.
- The district court certified the decision for interlocutory appeal; the government challenged the scope of the duties imposed and the breadth of the equitable relief.
- The court of appeals largely affirmed and sustained the district court’s authority to order structural relief, while requiring limited modifications to certain descriptions.

## Issues

1. Whether Interior and Treasury, as federal “trustee-delegates,” owe enforceable fiduciary duties to IIM beneficiaries, including duties stated in the American Indian Trust Fund Management Reform Act of 1994.
2. Whether IIM beneficiaries are entitled to a complete and accurate accounting of trust funds, including an historical accounting without regard to when funds were deposited.
3. Whether the claims were judicially reviewable notwithstanding the absence of “final agency action” under the Administrative Procedure Act.
4. Whether the district court exceeded equitable authority by ordering structural injunctive relief, remanding to the agencies, retaining jurisdiction, and requiring periodic reporting.
5. Whether agency interpretations narrowing trust duties were entitled to Chevron deference.

## Decision

- The district court entered declaratory and injunctive relief, finding Interior and Treasury in breach of fiduciary obligations owed to IIM beneficiaries.
- The district court declared defendants had a duty to provide an accurate accounting of all IIM trust money and to perform an historical accounting.
- The district court ordered agencies to preserve and assemble trust information, adopt written policies and procedures to address missing information, and proceed with an historical accounting, while retaining jurisdiction and requiring quarterly status reports.
- On interlocutory appeal, the D.C. Circuit affirmed in relevant part, holding the district court could adjudicate the claims absent final agency action.
- The D.C. Circuit found ample evidence supporting findings of ongoing material breaches of fiduciary duties.
- The D.C. Circuit held the structural relief, including retained jurisdiction and reporting, was within the district court’s equitable powers, while directing limited modifications to certain characterizations.

## Legal Principles

- When the United States controls and manages trust property for individual Indian beneficiaries, responsible agencies owe enforceable fiduciary duties consistent with the trust relationship and applicable statutes.
- The 1994 American Indian Trust Fund Management Reform Act imposes judicially enforceable duties to maintain adequate accounting and reporting systems, controls over receipts and disbursements, reconciliations to ensure accuracy, and periodic statements to beneficiaries.
- Beneficiaries may seek equitable relief to remedy an agency’s ongoing failure to perform legally required trust duties; review is not barred solely because the challenged conduct is not a single discrete “final agency action.”
- Federal courts may use equitable powers to craft structural remedies to address ongoing breaches of trust duties, including remand to agencies coupled with retained jurisdiction and periodic reporting to ensure compliance.
- Chevron deference does not authorize agency interpretations that effectively defeat or nullify statutory trust obligations owed to beneficiaries.

## Conclusion

The courts held that Interior and Treasury had ongoing fiduciary and statutory duties to properly account for and manage IIM trust funds, including providing a comprehensive historical accounting, and they approved structural equitable relief to compel and monitor compliance despite the government’s objections based on APA finality and administrative deference.


Cobell v. Norton, 91 F. Supp. 2d 1 (D.D.C. 1999), aff’d in relevant part, 240 F.3d 1081 (D.C. Cir. 2001)