| Cayuga Indian Nation of N.Y. v. Pataki | |
|---|---|
 | |
| Court | United States Court of Appeals for the Second Circuit |
| Full case name | Cayuga Indian Nation of N.Y. v. George Pataki, as Governor of the state of New York |
| Argued | March 31 2004 |
| Decided | June 28 2005 |
| Citation | 413 F.3d 266 (2d Cir. 2005) |
| Case history | |
| Prior history | 89 F.R.D. 627 (N.D.N.Y. 1981) (certifying class); 565 F. Supp. 1297 (N.D.N.Y. 1983) (denying motion to dismiss); 667 F. Supp. 938 (N.D.N.Y. 1987) (granting partial summary judgement); 730 F. Supp. 485 (N.D.N.Y. 1990) (invalidating 1795 and 1807 conveyances); 758 F. Supp. 107 (N.D.N.Y. 1991) (interpreting treaty); 771 F. Supp. 19 (N.D.N.Y. 1991) (rejecting laches defense); 1999 WL 224615 (N.D.N.Y. 1999) (ruling on damages calculation); 1999 WL 509442 (N.D.N.Y. 1999) (denying ejectment remedy); 79 F. Supp. 2d 66 (N.D.N.Y. 1999) (ordering separate trials); 79 F. Supp. 2d 78 (N.D.N.Y. 1999) (ruling on jury instructions); 83 F. Supp. 2d 318 (N.D.N.Y. 2000) (ruling on expert witnesses); 2000 WL 654963 (N.D.N.Y. 2000) (clarifying laches instruction); 165 F. Supp. 2d 266 (N.D.N.Y. 2001) (upholding jury award); 188 F. Supp. 2d 223 (N.D.N.Y. 2002) (denying post-trial motions) |
| Subsequent history | Cert. denied, 547 U.S. 1128 (2006) |
| Holding | |
| Laches bars all aboriginal title claims sounding in ejectment or trespass | |
| Court membership | |
| Judges sitting | José A. Cabranes, Rosemary S. Pooler, Janet C. Hall (D. Conn., sitting by designation) |
| Case opinions | |
| Majority | Cabranes, joined by Pooler |
| Dissent | Hall |
| Laws applied | |
| 25 U.S.C. § 177 | |
Cayuga Indian Nation of New York v. Pataki, 413 F.3d 266 (2d Cir. 2005), is an important precedent in the United States Court of Appeals for the Second Circuit for the litigation of aboriginal title in the United States. Applying the U.S. Supreme Court's recent ruling in City of Sherrill v. Oneida Indian Nation of New York (2005), a divided panel held that the equitable doctrine of laches bars all tribal land claims sounding in ejectment or trespass, for both tribal plaintiffs and the federal government as plaintiff-intervenor.
The ruling was the culmination of a two-decade-long litigation in the United States District Court for the Northern District of New York before Judge Neal Peters McCurn. Pursuant to a jury verdict, the Cayuga Nation of New York had been awarded $247.9 million, representing the current fair market value and 204 years of rental value damages for 64,015 acres conveyed by the tribe to the state in violation of the Nonintercourse Act (including pre-judgement interest).
This precedent has effectively ended the viability of all aboriginal title litigation in the Second Circuit (Connecticut, New York, and Vermont), the site of nearly all of the unresolved Indian land claims in the United States.[1] Since the ruling, no tribal plaintiff has overcome the laches defense in a land claim in the Second Circuit.[2] Four dissenting Supreme Court justices had previously adopted the view of the Second Circuit in County of Oneida v. Oneida Indian Nation of New York State (1985); there, the majority did not reach the issue.