## Facts

- The Seminole Nation sued the United States for money allegedly owed under the Treaties of 1856 and 1866 and related statutes governing tribal funds.
- After an initial recovery was reversed for lack of jurisdiction, Congress enacted a special jurisdictional statute permitting renewed litigation.
- In the Court of Claims, the Nation asserted six claims; the court allowed one in full and two in part, calculated a net award of $18,388.30, but applied gratuity offsets totaling $705,337.33 and dismissed the petition.
- The Nation sought Supreme Court review of five claims disallowed in whole or in part and challenged the propriety of offsetting gratuities.
- Claims implicated: (a) alleged diversion of 1856 treaty annuities; (b) school-support payments under the 1866 treaty; (c) alleged failure to build agency buildings promised in 1866; and (d) administration of an 1856 treaty trust fund requiring per capita annuity payments.
- For 1870–1874, the United States, at the Seminole General Council’s request, paid annuity funds to the tribal treasurer and to designated creditors rather than directly to individual members; the record suggested possible corruption by tribal officials and potential federal notice of it.

## Issues

1. Whether the 1866 treaty released the Nation’s claim based on alleged diversion of sums promised under the 1856 treaty.
2. Whether school-support obligations under the 1866 treaty were satisfied by payments made to the tribal treasurer when schools actually received the benefit.
3. Whether a 1907 school-support payment to the U.S. Indian Agent was authorized by § 11 of the Act of Apr. 26, 1906 and discharged the treaty obligation.
4. Whether the United States breached the 1866 treaty obligation to construct suitable agency buildings costing no more than $10,000.
5. Whether, regarding 1856 treaty per capita annuities, the Court of Claims properly deducted overpayments and properly treated 1907–1909 payments to the Indian Agent as valid.
6. Whether 1870–1874 annuity payments made through the tribal treasurer and creditors discharged the United States’ trust obligation where federal officials knew or should have known of corruption and where beneficiaries may not have received the funds.

## Decision

- The Court affirmed disallowance of the claim for diverted 1856 treaty annuities, holding it was released by the 1866 treaty.
- The Court affirmed denial of recovery for school-support funds paid to the tribal treasurer because the schools actually received the benefit, regardless of any payment-formalities dispute.
- The Court upheld the 1907 school-support payment to the U.S. Indian Agent as authorized by § 11 of the 1906 Act and sufficient to satisfy the treaty obligation.
- The Court affirmed rejection of the claim that the United States breached the 1866 treaty obligation to construct suitable agency buildings.
- The Court affirmed deductions for overpayments and held the 1906 Act was not repealed by the later jurisdictional statute, validating 1907–1909 payments to the Indian Agent.
- The Court reversed in part and remanded the 1870–1874 annuity-payments issue for specific findings on corruption of the General Council, federal knowledge, and whether the Seminole people received the benefit of the disbursements.

## Legal Principles

- Later treaty provisions with clear release language can extinguish claims based on obligations under earlier treaties.
- Treaty payment obligations are satisfied where the intended tribal institution actually received the benefit of the funds, even if the payment channel is contested.
- Statutory authority directing payment to federal Indian agents remains effective absent repeal; later jurisdictional legislation does not impliedly revoke such administrative payment authority.
- The United States, when administering Indian funds, is treated as a trustee and is held to exacting fiduciary standards; it may not discharge trust obligations by routing funds through tribal officials if federal officers knew or should have known those officials were misappropriating funds and beneficiaries did not receive the benefit.
- When fiduciary breach turns on disputed conditions (corruption, notice, benefit), detailed fact-finding is required before determining whether the United States’ payments satisfied its obligations.

## Conclusion

The Court largely upheld the government’s defenses to the Nation’s treaty-based monetary claims, including treaty releases, satisfaction by beneficial use, and statutory authority for payments to an Indian Agent, but remanded to determine whether the United States violated its fiduciary duties by channeling per capita annuities through allegedly corrupt tribal leadership without ensuring the intended beneficiaries received the funds.


Seminole Nation v. United States, 316 U.S. 286 (1942)