Federal Indian Law

Note

Disenrollment as Citizenship Revocation: Promoting Tribal Sovereignty by Embracing International Norms

This Note argues that Indian tribes can best address disenrollment by viewing the problem through the lens of international norms regarding citizenship revocation. In choosing to embrace these norms, tribes can restrict disenrollment in a manner that does not simply invoke tribal sovereignty but instead promotes it.

Feb 28, 2025
Article

The Three Lives of Mamengwaa: Toward an Indigenous Canon of Construction

Many of the intractable political disputes that plague tribal nations can be traced to the reliance on legal principles that are poor fits in Indigenous contexts. I suggest the acknowledgment of an Indigenous canon of construction of tribal laws by tribal judiciaries that will benefit legal development in tribal nations.

Jan 30, 2025
Feature

Legislative Constitutionalism and Federal Indian Law

This Feature offers alternative strategies and visions for a less court-centered constitutionalism with a case study of federal Indian law and American colonialism—a case study that places not only Congress, but the philosophies and agency of Native people and nations at the center of our constitutional law and history.

May 31, 2023
Essay

The Power of Tribal Courts in Ongoing Environmental-Tort Litigation

The groundbreaking environmental tort-litigation across the country has overlooked the potential role of tribal courts. Using an original empirical analysis of over 300 cases, this Essay outlines tribal-court jurisdiction over environmental-tort cases in the wake of attacks on tribal sovereignty in the form of tribal jurisdiction stripping. 

Feb 17, 2023
Essay

Water Rights of Public Domain Allotments

This Essay argues that public domain allotments (PDAs) are Indian Country and entitled to federal reserved water rights. By comparing federal statutes creating allotments and using the Indian Canons of Construction, the Essay uses California as a case study to show that PDAs have rights to water outside state systems.

Feb 17, 2023
Note

Native Voting Power: Enhancing Tribal Sovereignty in Federal Elections

Restrictive voting laws not only infringe upon the rights of individual Native American citizens but also denigrate tribal sovereignty. This Note argues that to fulfill its trust obligation to tribes, Congress should require state election officials to form compacts with tribes governing the administration of federal elections.

Jan 31, 2023
Note

“We Hold the Government to Its Word”: How McGirt v. Oklahoma Revives Aboriginal Title

McGirt’s insistence on unambiguous proof of Congress’s intent created an opening for aboriginal-title suits against the United States. By enforcing the congressional-intent requirement, McGirt cleared the sovereign immunity and preclusion bars that have stymied such suits. An overlooked Tenth Circuit decision unknowingly demonstrated how courts can implement McGirt.

May 31, 2022
Article

Empire States: The Coming of Dual Federalism

In the standard account of federalism’s eighteenth-century origins, the Framers divided government power among two sovereigns to protect individual liberties. This Article offers an alternative history. It emphasizes that federalism was a form of centralization—a shift of authority from diffuse quasi-sovereigns into the hands of only two legitimate sovereigns.

May 9, 2019
Essay

Environmental Justice and Tribal Sovereignty: Lessons from Standing Rock

The Standing Rock protests represent the latest iteration of longstanding tribal dissent against an environmental law framework that overlooks their interests. This Essay contends that the environmental movement’s failure to advocate for the restoration of tribal sovereignty has also left intact a legal framework incapable of addressing climate change.

Jan 20, 2018
Essay

Oral Tradition and the Kennewick Man

In April 2016, the U.S. Army Corps of Engineers confirmedthat the ancient human body discovered in 1996 near Kennewick, Washington,often referred to as the “Kennewick Man” or “The Ancient One,” is geneticallyrelated to modern-day Native Americans. Thisconfirmation ended a twenty-year-long struggle between scientists at the Smithsonian, the U.S. Department of the Interior, and Native American tribes ofthe Columbia Plateau, and will now jumpstart the process for repatriation ofthe Kennewick Man to the Native American tribes for reburial in accordance withthe Native American Graves Protection and Repatriation Act of 1990 (NAGPRA).

Nov 3, 2016
Essay

Contract and (Tribal) Jurisdiction

Consider two commercial contracts. The first requires customers to waive their rights to bring class actions against large businesses in favor of private arbitration. The second requires a reservation leaseholder to adjudicate disputes in tribal court. Both contracts require dispute resolution in fora over which the Supreme Court does not exercise supervisory jurisdiction. Both arbitration and tribal courts are favored by acts of Congress. Both contracts are hotly contested in the Supreme Court. But the arbitration clause contract has been affirmed in a series of recent decisions. The tribal court contract, by contrast, is pending before the Court in Dollar General Corp. v. Mississippi Band of Choctaw Indians. Ironically, while the more conservative Justices signed on to the arbitration clause decisions, these same Justices may be Dollar General’s best bets for escaping tribal jurisdiction. This short Essay details the key arguments in Dollar General and argues that to undo the tribal contract would unnecessarily and unconstitutionally undo the right to contract for Indian nations.

Apr 11, 2016
Article

Beyond the Indian Commerce Clause

This Article uses unexamined historical sources to argues that the Indian Commerce Clause, open-ended when written, was a minor component of eighteenth-century constitutional thought. This history provides a more solid foundation for doctrinal principles derided as incoherent, and suggests more cabined federal authority over Indians than commonly thought.

Jan 15, 2015
Essay

(Re)Solving the Tribal No-Forum Conundrum: Michigan v. Bay Mills Indian Community

Michigan v. Bay Mills Indian Community, a dispute over a controversial off-reservation Indian casino, is the latest opportunity for the Supreme Court to address the doctrine of tribal sovereign immunity. The Court could hand Michigan a big win by broadly abrogating tribal immunity, and in turn wreak havoc on modern tribal governance. Alternately, the Court could hand Bay Mills a victory by affirming the tribe’s immunity, effectively precluding judicial review of the tribe’s casino project. In this Essay, Professor Matthew L.M. Fletcher argues that neither choice is preferable to a third option that would both advance tribal self-determination and hold tribes accountable to outsiders. The Court could condition tribal immunity in federal or state court on whether the tribe has solved the no-forum problem by providing a tribal forum for the resolution of important disputes.

Nov 18, 2013
Review

Lightning in the Hand: Indians and Voting Rights

120 Yale L.J. 1420 (2011).  American Indians and the Fight for Equal Voting Rights By Laughlin McDonald Norman, OK: University of Oklahoma Press, 2010, pp. 347. $55.00.

Apr 5, 2011
Article

In Defense of Property

118 Yale L.J. 1022 (2009). This Article responds to an emerging view, in scholarship and popular society, that it is normatively undesirable to employ property law as a means of protecting indigenous cultural heritage. Recent critiques suggest that propertizing culture impedes the free flow of ideas, speech, and perhaps culture itself. In our view, these critiques arise largely because commentators associate “property” with a narrow model of individual ownership that reflects neither the substance of indigenous cultural property claims nor major theoretical developments in the broader field of property law. Thus, departing from the individual rights paradigm, our Article situates indigenous cultural property claims, particularly those of American Indians, in the interests of “peoples” rather than “persons,” arguing that such cultural properties are integral to indigenous group identity or peoplehood, and deserve particular legal protection. Further, we observe that whereas individual rights are overwhelmingly advanced by property law’s dominant ownership model, which consolidates control in the title-holder, indigenous peoples often seek to fulfill an ongoing duty of care toward cultural resources in the absence of title. To capture this distinction, we offer a stewardship model of property to explain and justify indigenous peoples’ cultural property claims in terms of nonowners’ fiduciary obligations toward cultural resources. We posit that re-envisioning cultural property law in terms of peoplehood and stewardship more fully illuminates both the particular nature of indigenous claims and the potential for property law itself to embrace a broader and more flexible set of interests.

May 27, 2009
Note

Property Rights and Sacred Sites: Federal Regulatory Responses to American Indian Religious Claims on Public Land

113 Yale L.J. 1623 (2004) The courts and Congress have left sacred sites protection in the hands of land management agencies, and although many feared this decision would be disastrous, land agencies have actually embraced their role and sought to accommodate Indian religions and protect their sacred sites. Furthermore, agency accommodation is actually better for society as a whole than the broader judicial and legislative protections typically advocated by sacred sites supporters. Agency accommodation avoids the disadvantages of broad categorical protection while still serving as a strong method for preserving sacred sites. Although land agencies have had the role of sacred sites protectors thrust upon them, they seem to have turned out to be ideally suited for the job.

May 1, 2004