## Facts

- Hugh Lee, a non-Indian, operated a general store on the Navajo Reservation in Arizona under a federal trader’s license.
- Paul and Lorena Williams, Navajo tribal members, lived on the reservation and purchased goods from Lee on credit at the reservation store.
- Lee sued the Williamses in an Arizona state trial court to collect the alleged debt arising from the on-reservation transactions.
- The Williamses moved to dismiss, contending the Navajo tribal court had jurisdiction and the state court lacked authority.
- The state trial court denied the motion and entered judgment for Lee; the Arizona Supreme Court affirmed on the view that state jurisdiction was permitted absent an express congressional prohibition.
- The U.S. Supreme Court granted review to resolve the scope of state power over on-reservation civil disputes involving tribal members.

## Issues

1. Whether Arizona state courts may exercise civil jurisdiction over a debt-collection claim by a non-Indian against Navajo tribal members when the transaction occurred entirely on the Navajo Reservation.
2. Whether, absent congressional authorization, state-court jurisdiction in such circumstances impermissibly intrudes on tribal self-government and the authority of tribal courts.

## Decision

- The Supreme Court unanimously reversed.
- The Court held Arizona lacked jurisdiction over the suit and that the motion to dismiss should have been granted.
- The Court concluded that allowing state adjudication would undermine tribal court authority over reservation affairs and infringe the Navajo right of self-government recognized by treaty and not withdrawn by Congress.
- The proper forum for the claim was the Navajo tribal court.

## Legal Principles

- States may not exercise jurisdiction over civil claims arising on an Indian reservation against tribal members when doing so would undermine tribal courts and tribal self-government, unless Congress has authorized state jurisdiction.
- The governing inquiry is whether state action “infringe[s] on the right of reservation Indians to make their own laws and be ruled by them.”
- The absence of an express congressional prohibition does not create state jurisdiction over on-reservation Indian affairs; affirmative congressional authorization is required where state action would displace tribal authority.
- Non-Indians who enter reservation commerce may be subject to tribal adjudicatory authority for disputes arising from on-reservation dealings with tribal members, particularly where tribal courts provide a functioning forum.
- Treaty-recognized tribal self-government and the federal framework regulating Indian affairs operate to bar contrary state jurisdiction in core reservation matters.

## Conclusion

Arizona could not adjudicate a non-Indian trader’s on-reservation debt claim against Navajo tribal members because state-court jurisdiction would displace tribal court authority and intrude on tribal self-government; absent congressional authorization, such disputes belong in tribal court.


Williams v. Lee, 358 U.S. 217 (1959)