United States v. Kagama

United States v. Kagama
Supreme Court of the United States
Submitted May 10, 1886 Argued March 2, 1886
Full case name	United States v. Kagama, alias Pactah Billy, an Indian, and another.
Citations	118 U.S. 375 (more) 6 S. Ct. 1109; 30 L. Ed. 228; 1886 U.S. LEXIS 1939
Holding
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.
Court membership
Chief Justice Morrison Waite Associate Justices Samuel F. Miller · Stephen J. Field Joseph P. Bradley · John M. Harlan William B. Woods · Stanley Matthews Horace Gray · Samuel Blatchford
Case opinion
Majority	Miller, joined by unanimous
Laws applied
U.S. Const. Art. I, § 8, cl. 3; 18 U.S.C. § 1153

United States v. Kagama, 118 U.S. 375 (1886), was a landmark United States Supreme Court case that upheld the constitutionality of the Major Crimes Act of 1885.^[1] This Congressional act gave the federal courts jurisdiction in certain Indian-on-Indian crimes, even if they were committed on an Indian reservation. Kagama, a Yurok Native American (Indian) accused of murder, was selected as a test case by the Department of Justice to test the constitutionality of the Act.

The importance of the ruling in this particular case was that it tested the constitutionality of the Act and confirmed Congress's authority over Indian affairs. Plenary power over Indian tribes, supposedly granted to the U.S. Congress by the Commerce Clause of the Constitution, was deemed not necessary to support the Supreme Court's decision. Instead, the Court found that the power derived from the tribes' status as dependent domestic nations. This recognition allowed Congress to pass the Dawes Act the following year. The case has been criticized by legal scholars as drawing on powers that are not granted to Congress by the Constitution, but it remains good law.