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Becerra v. San Carlos Apache Tribe

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Supreme Court of the United States
Becerra v. San Carlos Apache Tribe
Term: 2023
Important Dates
Argued: March 25, 2024
Decided: June 6, 2024
Outcome
affirmed
Vote
5-4
Majority
Chief Justice John Roberts • Sonia Sotomayor • Elena Kagan • Neil Gorsuch • Ketanji Brown Jackson
Dissenting
Brett Kavanaugh • Clarence Thomas • Samuel Alito • Amy Coney Barrett

Becerra v. San Carlos Apache Tribe is a case that was decided by the Supreme Court of the United States on June 6, 2024, during the court's October 2023-2024 term. The case was argued before the Court on March 25, 2024.

Together with Becerra v. Northern Arapaho Tribe, on certiorari to the Tenth Circuit, the Court affirmed the Ninth Circuit's ruling in a 5-4 vote, holding that "[The Indian Self-Determination and Education Assistance Act (ISDA)] requires [Indian Health Service (IHS)] to pay the contract support costs that a tribe incurs when it collects and spends program income to further the functions, services, activities, and programs transferred to it from IHS in a self-determination contract." Chief Justice John Roberts delivered the majority opinion of the court. Justice Brett Kavanaugh filed a dissenting opinion, joined by Justices Clarence Thomas, Samuel Alito, and Amy Coney Barrett.[1] Click here for more information about the ruling.

HIGHLIGHTS
  • The issue: The case concerned the Indian Health Service and contract support costs Click here to learn more about the case's background.
  • The questions presented: "Whether IHS must pay "contract support costs" not only to support IRS-funded activities, but also to support the tribe's expenditure of income collected from third parties."[2]
  • The outcome: The U.S. Supreme Court affirmed the United States Court of Appeals for the Ninth Circuit ruling.


    • Becerra v. San Carlos Apache Tribe came on a writ of certiorari to the United States Court of Appeals for the Ninth Circuit. Click here to review the lower court's opinion.

    Becerra v. Northern Arapaho Tribe came on a writ of certiorari to the United States Court of Appeals for the Tenth Circuit. Click here to review the lower court's opinion.

    Timeline

    The following timeline details key events in Becerra v. San Carlos Apache Tribe:

    The following timeline details key events in Becerra v. Northern Arapaho Tribe:

    Background

    In an effort to promote tribal sovereignty, the Indian Self-Determination and Education Assistance Act (ISDA) was passed by Congress in 1975. The ISDA permits qualifying Native American tribes to administer healthcare programs. The Indian Health Service (IHS) funded and managed these programs. Congress required IHS to provide contract support costs to tribes to alleviate issues related to insufficient bureaucratic and legal structure. Congress also allowed tribes to directly bill outside insurers. When tribes billed outside insurers directly, they had trouble funding these services without IHS contract support costs.[3][4][5][6][7] [2]

    Becerra v. San Carlos Apache Tribe

    The San Carlos Apache Tribe sued the U.S. Department of Health & Human Services, IHS, and the United States for the contract support costs. The United States District Court for the District of Arizona dismissed the claims for reimbursement. The United States Court of Appeals for the Ninth Circuit reversed and remanded the lower court's dismissal under 25 U.S.C. § 5325(a).[3][4][6][7]

    Becerra v. Northern Arapaho Tribe

    The Northern Arapaho Tribe also sued. The United States District Court for the District of Wyoming dismissed their case. The United States Court of Appeals for the Tenth Circuit reversed and remanded the lower court's decision.[5]

    Questions presented

    The petitioner presented the following questions to the court:[2]

    Questions presented:
    “ Whether IHS must pay "contract support costs" not only to support IRS-funded activities, but also to support the tribe's expenditure of income collected from third parties

    [8]

    		”

    Oral argument

    Audio

    Audio of oral argument:[9]



    Transcript

    Transcript of oral argument:[10]

    Outcome

    Together with Becerra v. Northern Arapaho Tribe, on certiorari to the Tenth Circuit, the Court affirmed the Ninth Circuit's ruling in a 5-4 vote, holding that "[The Indian Self-Determination and Education Assistance Act (ISDA)] requires [Indian Health Service (IHS)] to pay the contract support costs that a tribe incurs when it collects and spends program income to further the functions, services, activities, and programs transferred to it from IHS in a self-determination contract."[1] Chief Justice John Roberts delivered the majority opinion of the court. Justice Brett Kavanaugh filed a dissenting opinion, joined by Justices Clarence Thomas, Samuel Alito, and Amy Coney Barrett.


    Opinion

    In the court's majority opinion, Chief Justice John Roberts wrote:[1]

    “ Contract support costs are necessary to prevent a funding gap between tribes and IHS. By definition, these are costs that IHS does not incur when it provides healthcare services funded by congressional appropriations and third-party income. §§5325(a)(2)(A) and (B). But they are costs that tribes must bear when they provide, on their own,healthcare services funded by the Secretarial amount and program income. If IHS does not cover costs to support a tribe’s expenditure of program income, the tribe would have to divert some program income to pay such costs, or it would have to pay them out of its own pocket. Either way, the tribe would face a systemic funding shortfall relative to IHS—a penalty for pursuing self-determination.


    The self-determination contracts of the San Carlos Apache Tribe and Northern Arapaho Tribe require them to collect and spend program income to further the functions, services, activities, and programs transferred to them from IHS. When the Tribes do so and incur administrative costs, ISDA requires IHS to pay those support costs.[8]

    		”
    —Chief Justice John Roberts


    Dissenting opinion

    Justice Brett Kavanaugh filed a dissenting opinion, joined by Justices Clarence Thomas, Samuel Alito, and Amy Coney Barrett.

    In his dissent, Justice Kavanaugh wrote:[1]

    “ For the past 30 years, the Executive Branch has interpreted the relevant statutory provisions, 25 U. S. C. §§5325–5326, to require tribes to pay those overhead costs out of the third-party income collected from Medicare, Medicaid, and private insurers. And Congress has never overturned that consistent Executive Branch practice.


    But today, the Court upends that long-settled understanding and requires the Federal Government to furnish additional funding to the tribes for the costs of spending the third-party income. I respectfully dissent.[8]

    		”
    —Justice Brett Kavanaugh

    Text of the opinion

    Read the full opinion here.


    October term 2023-2024

    See also: Supreme Court cases, October term 2023-2024

    The Supreme Court began hearing cases for the term on October 2, 2023. The court's yearly term begins on the first Monday in October and lasts until the first Monday in October the following year. The court generally releases the majority of its decisions in mid-June.[11]


    See also

    External links

    Footnotes

    1. ↑ 1.0 1.1 1.2 1.3 U.S. Supreme Court, Becerra v. San Carlos Apache Tribe, decided June 6, 2024
    2. ↑ 2.0 2.1 2.2 Supreme Court of the United States 23-250 BECERRA V. SAN CARLOS APACHE TRIBE: "Questions presented," accessed November 27, 2023 Cite error: Invalid <ref> tag; name "qp" defined multiple times with different content
    3. ↑ 3.0 3.1 United States Court of Appeals for the Tenth Circuit "N. Arapaho Tribe v. Becerra," Mar 6, 2023
    4. ↑ 4.0 4.1 Supreme Court of the United States "XAVIER BECERRA, SECRETARY OF HEALTH AND HUMAN SERVICES, ET AL. v. NORTHERN ARAPAHO TRIBE, PETITION FOR A WRIT OF CERTIORARI," September 15, 2023
    5. ↑ 5.0 5.1 Supreme Court of the United States "XAVIER BECERRA, SECRETARY OF HEALTH AND HUMAN SERVICES, ET AL. v. NORTHERN ARAPAHO TRIBE, BRIEF OF RESPONDENT," October 11, 2023
    6. ↑ 6.0 6.1 Supreme Court of the United States "XAVIER BECERRA, SECRETARY OF HEALTH AND HUMAN SERVICES, ET AL. v. NORTHERN ARAPAHO TRIBE, REPLY BRIEF FOR THE PETITIONERS," October 24, 2023
    7. ↑ 7.0 7.1 Oyez "Becerra v. San Carlos Apache Tribe," accessed February 21, 2024
    8. ↑ 8.0 8.1 8.2 Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
    9. ↑ Supreme Court of the United States, "Oral Argument - Audio," argued March 25, 2024
    10. ↑ Supreme Court of the United States, "Oral Argument - Transcript," argued March 25, 2024
    11. ↑ SupremeCourt.gov, "The Supreme Court at Work: The Term and Caseload," accessed January 24, 2022
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