United States v. Sandoval
| United States v. Sandoval | |
|---|---|
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| Argued February 27, 1913 Decided October 20, 1913 |
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| Full case name | United States v. Sandoval |
| Citations | 231 U.S. 28 (more) |
| Prior history | 198 F. 539 (D.N.M. 1912) |
| Holding | |
| Generally applicable federal Indian statutes apply to the Pueblo | |
| Court membership | |
| Case opinions | |
| Majority | Devanter |
United States v. Sandoval, 231 U.S. 28 (1913), was a case decided by the United States Supreme Court.
The King of Spain granted formal title to the Pueblo people in 1689. Mexico ceded most of what is today New Mexico to the United States in 1848 under the Treaty of Guadalupe Hidalgo. New Mexico was a territory until January 6, 1912, when it became the forty seventh state to be added to the United States. Previous decisions of the US Supreme Court held that the Nonintercourse Act did not restrict the alienability of Pueblo peoples or lands. When the Supreme Court reversed its position in 1913, the land title to much of the state was called into question. Justice Miller of the Supreme Court had previously ruled, "Every person who makes a settlement on any lands belonging, secured, or granted by treaty with the United States to any Indian tribe, or surveys or attempts to survey said lands, or to designate any of the boundaries by marking trees or otherwise, is liable to a penalty of $1,000."
Congress responded in 1924 and 1933 with compromise legislation to extinguish some aboriginal title and to establish procedures for determination and compensation. In United States v. Sandoval, 231 U.S. 28 (1913), the question before the Supreme Court was whether Pueblo lands, which were owned by land grants with the Spanish government and later recognized by the United States after the Mexican–American War, were "owned" by the Pueblo peoples. The case involved the sale of alcohol by a non-Indian, Felipe Sandoval, to the Pueblo of New Mexico at the San Juan Village. Sandoval argued such sales were legal, based on decisions territorial court since 1905. New Mexico become a State in 1912. The Statehood Act acknowledged Pueblo lands as "Indian Country" defined as "distinctly Indian communities, recognized and treated by the government as dependent communities entitled to federal protection." The court ultimately ruled that it was for Congress alone to determine when guardianship over Indians should cease. The citizenship of Indians did not prevent Congress from enacting laws to protect and benefit tribes.
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