Facts
- Congress enacted § 9 of the Indian Appropriations Act of 1885 (the Major Crimes Act), making specified major crimes committed by Indians in “Indian country” triable in federal court when committed on a reservation within a state.
- Kagama (also known as Pactah Billy), an Indian residing on the Hoopa Valley Indian Reservation in California, was indicted in federal circuit court for murdering Iyouse (also known as Ike), another Indian on the same reservation.
- Mahawaha (also known as Ben) was charged as an aider and abettor in the alleged murder.
- The case was used to test whether Congress could constitutionally confer federal criminal jurisdiction over Indian-on-Indian major crimes occurring on a reservation located within a state.
Issues
- Whether Congress may constitutionally grant federal courts jurisdiction to try an Indian for murdering another Indian on an Indian reservation located wholly within a state.
- Whether § 9 of the Major Crimes Act is a valid federal law in its application to major crimes committed by Indians in Indian country within a state.
- Whether states, rather than the federal government, have authority to prosecute such crimes when the reservation is within state boundaries and the parties are Indians maintaining tribal relations.
Decision
- The Supreme Court unanimously upheld § 9 of the Major Crimes Act as constitutional.
- The Court held that federal courts have jurisdiction to try and punish an Indian for the listed major crimes committed against another Indian on an Indian reservation within a state.
- The Court sustained the indictment, rejecting the claim that federal jurisdiction was constitutionally absent.
Legal Principles
- Congress may confer federal criminal jurisdiction over specified major crimes committed by Indians in Indian country, including reservations located within states.
- State authority does not extend to tribes and tribal members maintaining tribal relations on reservations; states lack such power because tribal communities are not treated as owing allegiance to the state and are not protected by it in the relevant sense.
- Congressional authority in this area rests on the political relationship between the United States and Indian tribes as dependent communities under U.S. sovereignty, including a federal duty of protection that carries legislative power.
- The decision did not require a broad construction of the Indian Commerce Clause as the sole basis for jurisdiction; it sustained federal power on the basis of the federal government’s unique guardianship relationship and resulting authority in Indian affairs.
- When Congress expressly enacts a statute extending federal jurisdiction to Indian-on-Indian crimes in Indian country, federal courts may exercise that jurisdiction under the statute’s terms.
Conclusion
The Court upheld the Major Crimes Act and confirmed that Congress may place major crimes committed by Indians against other Indians on reservations within states under federal criminal jurisdiction, based on the federal government’s asserted protective authority over dependent tribal communities and the exclusion of state power where tribal relations continue.