Seminole Nation v. United States
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Decided: May 11, 1942
Citations: 316 U.S. 286, 62 S. Ct. 1049
Deciding Justices: Justice Murphy wrote for the majority. Chief Justice Jackson dissented. Justice Reed took no part in the decision.
Background: The Seminole Nation's claims for reimbursement related to provisions contained in the Treaty of August 7, 1856.
Case Summary: The Seminole Nation's claims for reimbursement, relating back to the Treaties of 1856 and 1866, were divided into five separate items. The Court dismissed the first claim for reimbursement, finding the Treaty of March 21, 1866 released the Government of its obligation to pay the outstanding balance owed under the Treaty of August 7, 1856. Two of the Nation's other reimbursement claims were disallowed upon the finding that the annual interest from the trust funds established under the Treaty of 1866 were, in fact, directed to their designated purposes (support of schools and the erection of an agency building).
Though three of the claims were found to be without merit, the Court reversed the lower court's judgment in regards to two of the five claims.
One such claim concerned language from Article VIII of the Treaty of 1856 which provided that the Government would establish a $500,000 trust fund with the annual interest going to the individual members of the Seminole Tribe. During the years 1870-1874, the Government made payments totaling $66,422.64. A portion of this amount was paid to the tribal treasurer and the remainder was paid to the designated creditors of the tribe. This arrangement for distribution was requested by the Seminole General Council.
The Seminole Nation argued that the Treaty was violated since annuity payments were made to the General Council when the Treaty stipulated that "payments were to be made per capita for the benefit of each individual Indian." The Court found the Government failed to fulfill its duty, citing "a well established principle of equity that a third party who pays money to a fiduciary for the benefit of the beneficiary, with knowledge that the fiduciary intends to misappropriate the money or otherwise be false to his trust, is a participant in the breach of trust and liable therefore to the beneficiary."
The Seminole Nation's last grievance was in regards to payments made "during the fiscal years 1899 to 1907," which totaled $864,702.58. These payments were made to the Seminole tribal treasurer. Though the Court found the Government did not act improperly by making payment to the treasurer (as the provision did not stipulate per capita distribution), the Court stated it could still be found liable if it violated its fiduciary duty in the manner discussed above. It was documented that the Commission of the Five Civilized Tribes notified Congress and the Secretary of the Interior of the general corruption of tribal governments before the payments were made to the Seminole treasurer. More pointedly, the Secretary of the Interior and the Commissioner of Indian Affairs were informed in January of 1898 of "complaints of misgovernment, venality, and fraudulent conduct on the part of Seminole leaders[.]"
The Court,
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