Duke Law School

Program in Public Law

United States v. Navajo Nation

The Navajo Nation filed a complaint against the United States for breach of trust and breach of contract. The United States, through the Secretary of the Interior, supervises and regulates the development and sale of mineral resources on Indian reservation lands, pursuant to the Indian Mineral Leasing Act (IMLA). The Navajo Nation complained that the United States acted in the interests of a coal mining company, and not in the interests of the Navajo Nation, when negotiating the rate of royalty payments owed on coal mined from Navajo land. The Court of Federal Claims dismissed the complaint, ruling that although the United States had breached its fiduciary obligations to the Navajo Nation, this breach was not actionable because the United States did not have a trust relationship with the Navajo Nation and monetary relief was not available. The court of appeals reversed, holding (1) that a trust relationship existed and exists with the Navajo Nation, and (2) monetary damages are an available remedy for breach of this trust.

Question Presented:
Whether the court of appeals properly held that the United States is liable to the Navajo Nation for up to $600 million in damages for breach of fiduciary duty in connection with the Secretary's actions concerning an Indian mineral lease, without finding that the Secretary had violated any specific statutory or regulatory duty established pursuant to the IMLA.

Decision under Review

Supreme Court Opinion