Lane v. Mickadiet
Annotate this Case
241 U.S. 201 (1916)
U.S. Supreme Court
Lane v. Mickadiet, 241 U.S. 201 (1916)
Lane v. Mickadiet
Argued April 10, 1916
Decided May 22, 1916
241 U.S. 201
The general rule that courts have no power to interfere with the performance by the Land Department of the administrative duties devolving upon it, although they may, when the functions of the Department are at end, correct, as between proper parties, errors of law committed by the Department in such administration, held to be applicable in this case, as no exception exists to take it out of the rule.
Under the Acts of May 8, 1906 and June 25, 1910, the Secretary of the Interior has exclusive authority and jurisdiction to determine the heirs of an allottee Indian who are entitled to succeed to the allotment made to him under the act of February 8, 1887, in case of his death during the restricted period, and this authority includes the right to reopen and review a previous administrative order on proper charges of newly discovered evidence or fraud while the property is still under administrative control.
A court has no power to issue a writ of mandamus to control the conduct of the Secretary of the Interior concerning a matter within his administrative authority.
43 App.D.C. 414 reversed.
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