United States v. Candelaria - 271 U.S. 432 (1926)
U.S. Supreme Court
United States v. Candelaria, 271 U.S. 432 (1926)
United States v. Candelaria
Argued November 18, 19, 1925
Decided June 1, 1926
271 U.S. 432
1. The Pueblo Indian tribes in New Mexico are dependent communities under the protective care of the United States, and their lands, though held by title in fee simple, are subject to the legislation of Congress enacted in the exercise of the government's guardianship. P. 271 U. S. 439.
2. The purpose of Congress to subject the lands of these Indians to such legislation has been made certain in various ways, including an act annulling and forbidding taxation of lands by the Territory
of New Mexico and provision of a special attorney to represent the Pueblo Indians and protect their interests. P. 271 U. S. 440.
3. The Pueblos are "Indian tribes" within the meaning of Rev.Stats. § 2116 (adopted in 1834), providing that
"no purchase, grant, lease, or other conveyance of lands, or of any title or claim thereto from any Indian nation or tribe of Indians, shall be of any validity in law or equity unless the same be made by treaty or convention entered into pursuant to the Constitution,"
and within the meaning of the Act of 1851, extending this provision, with others "regulating trade and intercourse with the Indian tribes," to "the Indian tribes" of New Mexico. P. 271 U. S. 441.
4. Under the Spanish and Mexican law, Pueblo Indians, although having full title to their lands, were regarded as in a state of tutelage, and could alienate their land only under governmental supervision. P. 271 U. S. 442.
5. Under territorial laws, sanctioned by Congress, a Pueblo community in New Mexico is a juristic person with capacity to sue and defend with respect to its lands. P. 271 U. S. 442.
6. But judgments against a Pueblo tribe in New Mexico, in suits brought by it to quiet title to its lands -- one in a territorial court concluded in the state courts after statehood, the other in the federal court -- did not bar the United States from afterwards maintaining a suit to quiet the title to the same lands against the same defendants, on behalf of the Indians, where the United States was not a party to the former litigation and the attorney therein representing the Indians did so without the United States' authority. P. 271 U. S. 443.
7. A state court of New Mexico has jurisdiction to enter a judgment in an action by an Indian Pueblo against opposing claimants concerning title to land which would be conclusive on the United States if it authorized the bringing and prosecution of the suit. P. 271 U. S. 444.
8. The question whether such a judgment disregarded an official survey of a Spanish or Mexican grant confirmed by Congress to the Indians relates to the merits, and not to the jurisdiction of the state court. P. 271 U. S. 444.
Response to question certified by the circuit court of appeals upon an appeal from a decree of the district court dismissing a bill brought. by the United States to quiet the title to certain lands in the Indian Pueblo of Laguna.