South Carolina v. Catawba Indian Tribe
| South Carolina v. Catawba Indian Tribe, Inc. | |
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| Argued Dec. 12, 1985 Decided June 2, 1986 |
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| Full case name | South Carolina v. Catawba Indian Tribe, Inc. |
| Docket nos. | 84-782 |
| Citations | 476 U.S. 498 (more)
106 S. Ct. 2039, 90 L. Ed. 2d 490, 54 USLW 4544
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| Prior history | 718 F.2d 1291 (4th Cir. 1983), affirmed on rehearing, 740 F.2d 305 (4th Cir. 1984) (en banc), cert. granted, 471 U.S. 1134 (1985) |
| Subsequent history | On remand, 865 F.2d 1444 (4th Cir. 1989) (en banc), cert. denied, 491 U.S. 906 (1989), mandamus denied after remand sub nom. In re Catawba Indian Tribe of S.C., No. 89-2831 (4th Cir. 1990) (en banc), aff'd in part, rev'd in part, vacated and remanded, 978 F.2d 1334 (4th Cir. 1992) (en banc), cert. denied, 507 U.S. 972 (1993), mandamus denied after remand sub nom. In re Catawba Indian Tribe of S.C., 973 F.2d 1133 (4th Cir. 1992) (en banc) |
| Holding | |
| State statutes of limitations apply to the land claims of terminated tribes | |
| Court membership | |
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| Case opinions | |
| Majority | Stevens, joined by Burger, Brennan, White, Powell, Rehnquist |
| Dissent | Blackmun, joined by Marshall, O'Connor |
| Laws applied | |
| Treaty of Fort Augusta; 25 U.S.C. §§ 931—938 (termination act); Nonintercourse Act | |
South Carolina v. Catawba Indian Tribe, Inc., 476 U.S. 498 (1986), is an important U.S. Supreme Court precedent for aboriginal title in the United States decided in the wake of County of Oneida v. Oneida Indian Nation of New York State (Oneida II) (1985). Distinguishing Oneida II, the Court held that federal policy did not preclude the application of a state statute of limitations to the land claim of a tribe that had been terminated, such as the Catawba tribe.
The Court remanded to the United States Court of Appeals for the Fourth Circuit to determine whether South Carolina's statute of limitations applied to the facts of the case. All together, the Fourth Circuit heard oral arguments in the case seven times, six of those times sitting en banc, i.e. all the judges on the Circuit rather than a panel of three (although the Circuit wrote only five published opinions). The Fourth Circuit determined that the limitations statute only barred the claim against those defendants that could satisfy the standards of adverse possession and upheld the trial court's denial of a defendant class certification.
These rulings would have required the Catawbas to file individual lawsuits against the estimated 60,000 landowners in the area. The complaints were prepared and printed, but the parties reached a settlement before the date on which the Catawbas would have been required to file the individual complaints. Congress ratified the settlement, extinguishing all aboriginal title held by the Catawbas in exchange for $50,000,000—$32,000,000 paid by the federal government and $18,000,000 paid by the state.
The Treaty of Fort Augusta (1763), which immediately followed the Royal Proclamation of 1763, between the Catawba and the King of England guaranteed 144,000 acres of land to the Catawba in modern-day northern South Carolina. The "Tract of Land of Fifteen Miles square" was the Catawba's sole reservation, having ceded to the British the entirety of the rest of their claim to North and South Carolina in 1760 and 1763.
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