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Yellen v. Confederated Tribes of the Chehalis Reservation

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Supreme Court of the United States
Yellen v. Confederated Tribes of the Chehalis Reservation
Term: 2020
Important Dates
Argument: April 19, 2021
Decided: June 25, 2021
Outcome
Reversed and remanded
Vote
6-3
Majority
Sonia Sotomayor • Chief Justice John Roberts • Stephen Breyer • Samuel Alito • Brett Kavanaugh • Amy Coney Barrett
Dissenting
Neil Gorsuch • Clarence Thomas • Elena Kagan
This article is about the court case previously known as Mnuchin v. Confederated Tribes of the Chehalis Reservation; it became Yellen v. Confederated Tribes of the Chehalis Reservation when Janet Yellen became secretary of the Treasury.

Yellen v. Confederated Tribes of the Chehalis Reservation is a case argued before the Supreme Court of the United States during the court's October 2020-2021 term on April 19, 2021.[1] It was consolidated with Alaska Native Village Corporation Association v. Confederated Tribes of the Chehalis Reservation.

In a 6-3 ruling, the U.S. Supreme Court reversed the U.S. Court of Appeals for the D.C. Circuit's ruling and remanded the case for further proceedings, holding that Alaska Native Corporations (ANCs) are “Indian tribe[s]” under the Indian Self-Determination and Education Assistance Act (ISDA) and as a result, are eligible for CARES Act funding. Justice Sonia Sotomayor authored the court's majority opinion. Justice Neil Gorsuch filed a dissenting opinion, joined by Justices Clarence Thomas and Elena Kagan.[2]

HIGHLIGHTS
  • The case: In April 2020, the U.S. Department of the Treasury determined that Alaska Native Corporations (ANCs) were considered Indian tribes under the Indian Self-Determination and Education Assistance Act (ISDA), and were therefore eligible to receive Title V funds under the Coronavirus Aid, Relief, and Economic Security (CARES) Act. Three groups of recognized Indian tribes challenged the determination in federal district court, arguing that the corporations do not meet the standards defined under the CARES Act or ISDA in order to be considered Indian tribes and therefore should not qualify to receive Title V funds. The Treasury asserted that Congress specifically included ANCs in ISDA's definition of Indian tribes and as a result, the ANCs were eligible. The district court agreed and granted summary judgment to the government, and withheld funding distributions to ANCs pending an appeal. The plaintiff tribes appealed to the U.S. Court of Appeals for the D.C. Circuit. The court reversed the district court's rulings and held that ANCs were not eligible for Title V funding. Click here to learn more about the cases' background.
  • The issues: The cases concerned Alaska Native corporations and whether they qualify for Coronavirus Aid, Relief, and Economic Security (CARES) Act payments.
  • The questions presented: "Whether Alaska Native regional and village corporations established pursuant to the Alaska Native Claims Settlement Act are “Indian Tribe[s]” for purposes of the CARES Act, 42 U.S.C. 801(g)(1)."[3]
  • The outcome: The U.S. Supreme Court reversed the U.S. Court of Appeals for the D.C. Circuit's ruling and remanded the case for further proceedings.


    • The case came on a writ of certiorari to the United States Court of Appeals for the District of Columbia Circuit. To review the lower court's opinion in the consolidated cases, click here.[4]

    Timeline

    The following timeline details key events in the consolidated cases:

    • June 25, 2021: The U.S. Supreme Court reversed the U.S. Court of Appeals for the D.C. Circuit's ruling and remanded the case for further proceedings.
    • April 19, 2021: The U.S. Supreme Court heard oral argument.
    • January 8, 2021: The U.S. Supreme Court agreed to hear the cases. When the case was originally accepted by the U.S. Supreme Court, the case name was Mnuchin v. Confederated Tribes of the Chehalis Reservation.
    • October 23, 2020: Treasury Secretary Steven Mnuchin appealed to the U.S. Supreme Court.
    • September 25, 2020: The U.S. Court of Appeals for the D.C. Circuit reversed the U.S. District Court for the District of Columbia's grant of summary judgment to the government and its denial of summary judgment to the plaintiff tribes, and held that Alaska Native Corporations are not eligible for funding under Title V of the CARES Act.[4]

    Background

    Title V of the Coronavirus Aid, Relief, and Economic Security Act (CARES Act) makes funds available to the recognized governing bodies of any designated "Indian tribe", as defined in the Indian Self-Determination and Education Assistance Act (ISDA). Alaska Native Corporations (ANCs) are state-chartered corporations established by Congress to receive land and money provided to Alaska Natives in settlement of aboriginal land claims.[4] On April 13, 2020, the Department of the Treasury published a form seeking tribal data to help apportion Title V funds. On April 22, the Treasury confirmed that ANCs were eligible to receive Title V funds.[4]

    Between April 17 and 23, three separate groups of Indian tribes filed lawsuits in the United States District Court for the District of Columbia challenging the Treasury's determination. Collectively, the plaintiffs included six federally recognized tribes in Alaska and twelve federally recognized tribes in the lower 48 states. The tribes argued that ANCs are not "Indian tribes" as defined by the CARES Act or ISDA because they are not "recognized as eligible for the special programs and services provided by the United States to Indians because of their status as Indians."[4] The government agreed that ANCs are not and could not be recognized, but Congress expressly included ANCs within the ISDA definition and as a result, the Treasury had to proceed accordingly.[4]

    The district court consolidated the three cases and granted an injunction halting the distribution of any Title V funds to ANCs. As a result, the government withheld distribution of the funds. Several ANCs and ANC associations then intervened, or joined the proceedings, as defendants. Ultimately, the district court granted summary judgment to the defendants, holding that the ANCs must qualify as Indian tribes under the CARES Act because they were specifically included in ISDA's definition of Indian tribes, despite the fact that no ANC has been recognized as an Indian tribe. Pending the results of an appeal, the Title V funds were not distributed to the ANCs.[4]

    On appeal, the United States Court of Appeals for the District of Columbia Circuit held that the ANCs were not eligible for funding under Title V of the CARES Act, reversed the district court's summary judgment grant to the defendants and the denial of summary judgment to the plaintiff tribes.[4]

    Definitions

    "Indian tribe"

    The definition of "Indian tribe" under the Indian Self-Determination and Education Assistance Act (ISDA) reads as follows:[5]

    “ (e) "Indian tribe" means any Indian tribe, band, nation, or other organized group or community, including any Alaska Native village or regional or village corporation as defined in or established pursuant to the Alaska Native Claims Settlement Act (85 Stat. 688) [ 43 U.S.C. 1601 et seq.], which is recognized as eligible for the special programs and services provided by the United States to Indians because of their status as Indians;[6] ”

    Questions presented

    The petitioner presented the following questions to the court:[3]

    Questions presented:
    • Whether Alaska Native regional and village corporations established pursuant to the Alaska Native Claims Settlement Act are “Indian Tribe[s]” for purposes of the CARES Act, 42 U.S.C. 801(g)(1).

    Oral argument

    Audio

    Audio of oral argument:[7]



    Transcript

    Transcript of oral argument:[8]

    Outcome

    In a 6-3 ruling, the U.S. Supreme Court reversed the U.S. Court of Appeals for the D.C. Circuit's ruling and remanded the case for further proceedings, holding that Alaska Native Corporations (ANCs) are “Indian tribe[s]” under the Indian Self-Determination and Education Assistance Act (ISDA) and as a result, are eligible for CARES Act funding. Justice Sonia Sotomayor authored the court's majority opinion. Justice Neil Gorsuch filed a dissenting opinion, joined by Justices Clarence Thomas and Elena Kagan.[2]

    Opinion

    In the court's majority opinion, Justice Sonia Sotomayor wrote:[2]

    “ In March 2020, Congress passed the Coronavirus Aid, Relief, and Economic Security (CARES) Act, 134 Stat. 281. Title V of the Act allocates $8 billion of monetary relief to “Tribal governments.” 134 Stat. 502, 42 U.S.C. §801(a)(2)(B). Under the CARES Act, a “Tribal government” is the “recognized governing body of an Indian tribe” as defined in the Indian Self-Determination and Education Assistance Act (ISDA). §§801(g)(5), (1). ISDA, in turn, defines an “Indian tribe” as “any Indian tribe, band, nation, or other organized group or community, including any Alaska Native village or regional or village corporation as defined in or established pursuant to the Alaska Native Claims Settlement Act[,] which is recognized as eligible for the special programs and services provided by the United States to Indians because of their status as Indians.” 25 U.S.C. §5304(e).


    The Department of the Treasury asked the Department of the Interior, the agency that administers ISDA, whether Alaska Native Corporations (ANCs) meet that definition. Consistent with its longstanding view, the Interior Department said yes. The Treasury Department then set aside approximately $500 million of CARES Act funding for the ANCs. The question presented is whether ANCs are “Indian tribe[s]” under ISDA, and are therefore eligible to receive the CARES Act relief set aside by the Treasury Department. The Court holds that they are.

    ... The Court today affirms what the Federal Government has maintained for almost half a century: ANCs are Indian tribes under ISDA. For that reason, they are Indian tribes under the CARES Act and eligible for Title V funding. The judgment of the Court of Appeals for the District of Columbia Circuit is reversed, and the cases are remanded for further proceedings consistent with this opinion.[6]

    		”
    —Justice Sonia Sotomayor

    Dissenting opinion

    Justice Neil Gorsuch filed a dissenting opinion, joined by Justices Clarence Thomas and Elena Kagan.

    In his dissent, Justice Gorsuch wrote:[2]

    “ The Coronavirus Aid, Relief, and Economic Security Act (CARES Act) directed trillions of dollars to various recipients across the Nation to help them address the COVID–19 pandemic. Our case focuses on $8 billion Congress set aside for “Tribal governments.” The question we must answer is whether Alaska’s for-profit Alaska Native Corporations (ANCs) qualify as “Tribal governments.” If they do, they may receive approximately $450 million of the earmarked funds; if not, the money will go to tribes across the country. The Court of Appeals for the District of Columbia Circuit wrote a thoughtful and unanimous opinion holding that ANCs are not “Tribal governments.” Today, the Court disagrees, providing two competing theories for its result. Respectfully, I find neither persuasive and would affirm.


    ... In my view, neither of the Court’s alternative theories for reversal can do the work required of it. The recognition clause denotes the formal recognition between the federal government and a tribal government that triggers eligibility for the full panoply of special benefits given to Indian tribes. Meanwhile, a fair reading of that clause indicates that it applies to ANCs. Accordingly, with respect, I would affirm.[6]

    		”
    —Justice Neil Gorsuch

    Text of the opinion

    Read the full opinion here.

    October term 2020-2021

    See also: Supreme Court cases, October term 2020-2021

    The Supreme Court began hearing cases for the term on October 5, 2020. 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.[9]

    The court issued 67 opinions during its 2020-2021 term. Two cases were decided in one consolidated opinion. Ten cases were decided without argument. Click here for more information on the court's opinions.

    The court agreed to hear 62 cases during its 2020-2021 term. Of those, 12 were originally scheduled for the 2019-2020 term but were delayed due to the coronavirus pandemic. Five cases were removed from the argument calendar.


    See also

    External links

    Footnotes

    1. ↑ When the case was originally accepted by the U.S. Supreme Court, the case name was Mnuchin v. Confederated Tribes of the Chehalis Reservation.
    2. ↑ 2.0 2.1 2.2 2.3 U.S. Supreme Court, Yellen v. Confederated Tribes of the Chehalis Reservation, decided June 25, 2021
    3. ↑ 3.0 3.1 Supreme Court of the United States, "Mnuchin v. Confederated Tribes: Questions presented," accessed January 9, 2021
    4. ↑ 4.0 4.1 4.2 4.3 4.4 4.5 4.6 4.7 U.S. Court of Appeals for the D.C. Circuit, Confederated Tribes v. Mnuchin, decided September 25, 2020
    5. ↑ Title 25, United States Code, "Section 5304 - Definitions," accessed January 13, 2021
    6. ↑ 6.0 6.1 6.2 Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
    7. ↑ Supreme Court of the United States, "Oral Argument - Audio," accessed April 20, 2021
    8. ↑ Supreme Court of the United States, "Oral Argument - Transcript," accessed April 20, 2021
    9. ↑ SupremeCourt.gov, "A Brief Overview of the Supreme Court," accessed April 20, 2015
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