United States v. Kagama

United States v. Kagama 118 U.S. 375, 6 S.Ct. 1109, 30 L.Ed. 228 (1886) was a United States Supreme Court ruling that upheld the Constitutionality of the Major Crimes Act of 1885. This Congressional Act gave the federal courts jurisdiction in certain cases of crimes between Native Americans, even if the crimes were committed on an Indian Reservation. The importance of the ruling in this case was that it upheld the constitutionality of a Congressional act that held plenary power over Indian affairs. This plenary power, granted to the U.S. Congress by the Supreme Court, allowed Congress to pass the Dawes Act the following year.

Background of the case

Kagama, a Klamath Indian also known as Pactah Billy, was on trial for murder of Iyouse, another Klamath Indian, on a Hoopa reservation in June 1885. After Kagama was indicted by the U.S. federal court in San Francisco, his appeal received a division of opinion (on the matter of jurisdiction) from the circuit court, before being heard by the Supreme Court in 1886.

In a similar case, Ex Parte Crow Dog 109 U.S. 556, 3 S.Ct. 396, 27 L.Ed. 1030 (1883), the Supreme Court had ruled that the federal government did not have jurisdiction in a case involving the murder of an American Indian by another American Indian. Justice Thomas Stanley Matthews wrote the decision for the court. In this decision, Justice Matthews explained that the reason the federal court did not have jurisdiction was because there was no law passed by U.S. Congress explicitly giving it jurisdiction over crimes between Native Americans.

Congress responded to the court's ruling by passing the Major Crimes Act of 1885, which very explicitly gave the federal government jurisdiction in certain major crimes (the murder of an American Indian, by an American Indian, was included) committed by American Indians, or on Indian Reservations.

The Court's decision

In a unanimous decision, authored by Justice Samuel Freeman Miller, the Supreme Court ruled that the Major Crimes Act was Constitutional, and, therefore, the case was within the jurisdiction of the federal courts. This ruling meant that the San Francisco Court's indictment would stand.

Consequences of the ruling

U.S. v. Kagama was the case that upheld Congress' plenary power over the Native American tribes in the late 19^th century. It reaffirmed Congress' power to pass legislation, including the Dawes Act, that would take away many of the liberties that Native Americans had been able to hold on to up until that point. 19^th and early 20^th century U.S. lawmakers viewed the American Indians as inferior people who would benefit from being assimilated into the Euro-American culture. The laws that followed the Kagama ruling were attempts to destroy the Native American cultural differences and force these tribes to share the Euro-American culture viewed by these lawmakers to be the superior culture.

See also

• List of United States Supreme Court cases, volume 118

References

• Full text opinion from Justia.com

• Ex Parte Crow Dog, 109 U.S. 556, 3 S.Ct. 396, 27 L.Ed. 1030 (1883)

• United States v. Kagama, 118 U.S. 375, 6 S.Ct. 1109, 30 L.Ed. 228 (1886)

• Weiner, Mark S. (2006). Americans Without Law: The Racial Boundaries of Citizenship, New York: New York University Press. ISBN 0-8147-9364-9

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