Cherokee Nation of Okla. v. Leavitt, 543 U.S. 631 (2005)
Primary Holding
The Government's promises to pay contract support costs to Indian tribes under the Indian Self-Determination and Education Assistance Act are legally binding, even if Congress did not appropriate sufficient funds for those costs.
In the case of Cherokee Nation of Oklahoma v. Leavitt, the Supreme Court decided that the U.S. government must honor its promises to pay certain costs to Indian tribes, even if Congress didn't set aside enough money for those payments. This is important because it ensures that tribes can rely on the government to fund services they provide, like healthcare, which helps protect the rights and well-being of their communities. This ruling is relevant for consumers when they are dealing with services provided by Indian tribes, as it reinforces that these tribes have a legal right to the funding they were promised, which can affect the quality and availability of services they receive.
AI-generated plain-language summary to help you understand this case
In Cherokee Nation of Oklahoma v. Leavitt, the underlying dispute arose from agreements between the United States government and two Indian tribes, the Cherokee Nation and the Shoshone-Paiute Tribes, regarding the payment of "contract support costs" incurred by the tribes during fiscal years 1994 through 1997. These contracts were established under the Indian Self-Determination and Education Assistance Act, which allows tribes to provide federally funded services, such as health services, that would otherwise be managed by government agencies. Each contract included an Annual Funding Agreement in which the government promised to pay for these costs. However, the government later refused to pay the full amounts owed, citing insufficient congressional appropriations. The procedural history of the case began with administrative proceedings initiated by the tribes, who submitted claims for payment under the Contract Disputes Act and the Indian Self-Determination Act to the Department of the Interior. The Department denied their claims, leading the tribes to seek legal recourse by filing a breach-of-contract lawsuit. The cases were brought before the United States Court of Appeals for the Tenth Circuit and the Federal Circuit, which ultimately resulted in the Supreme Court granting writs of certiorari to resolve the dispute regarding the binding nature of the government's promises. The relevant background context includes the framework established by the Indian Self-Determination and Education Assistance Act, which was designed to empower tribes by allowing them to manage federal programs and receive funding for the associated costs. The Act specifies that contract support costs, which include both direct and indirect expenses incurred by tribes in fulfilling their contractual obligations, must be covered by the government. This case highlights the ongoing tension between federal funding limitations and the commitments made to tribal governments, as well as the legal interpretation of those commitments in the context of the Act.
Whether the Government's promises to pay contract support costs to Indian tribes under the Indian Self-Determination and Education Assistance Act are legally binding.
The judgment is reversed and remanded.
- Court
- Supreme Court
- Decision Date
- November 9, 2004
- Jurisdiction
- federal
- Case Type
- landmark
- Damages Awarded
- N/A
- Data Quality
- high
City of Sherrill v. Oneida Indian Nation of N. Y., 544 U.S. 197 (2005)
Consumer LostThe Oneida Indian Nation cannot unilaterally revive its ancient sovereignty over lands purchased in an open market, as they have long relinquished governmental authority, and such a revival would disrupt the established governance of local municipalities.
Orff v. United States, 545 U.S. 596 (2005)
Consumer LostCongress did not waive the United States' sovereign immunity for suits brought by third-party beneficiaries under the Reclamation Reform Act of 1982, and therefore, individuals who are not parties to a government contract cannot sue the United States for breach of that contract.
Wagnon v. Prairie Band Potawatomi Nation, 546 U.S. 95 (2005)
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Commissioner v. Banks, 543 U.S. 426 (2005)
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