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|Prior=Plaintiff convicted in Gwinnett County, Georgia by the Georgia Superior Court (Sept. 15, 1831) |
|Prior=Plaintiff convicted in Gwinnett County, Georgia by the Georgia Superior Court (Sept. 15, 1831) |
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|Subsequent=None |
|Subsequent=None |
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|Holding=Worcester's conviction is void, because states have no criminal jurisdiction in Indian Country |
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|Holding=States were not permitted to redraw the boundaries of Indian lands or forbid residence in those territories, because the Constitution granted sole authority to Congress to regulate relations with sovereign States. Superior Court of Gwinnett County, Georgia reversed and remanded. |
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|SCOTUS=1830-1834 |
|SCOTUS=1830-1834 |
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|Majority=Marshall |
|Majority=Marshall |
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|LawsApplied=[[Article One of the United States Constitution|U.S. Const. art. I]] |
|LawsApplied=[[Article One of the United States Constitution|U.S. Const. art. I]] |
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'''''Worcester v. Georgia''''', [[Case citation|31 U.S. (6 Pet.) 515]] (1832), was a case in which the [[Supreme Court of the United States|United States Supreme Court]] |
'''''Worcester v. Georgia''''', [[Case citation|31 U.S. (6 Pet.) 515]] (1832), was a case in which the [[Supreme Court of the United States|United States Supreme Court]] vacated the conviction of [[Samuel Worcester]], holding that the state of Georgia had no criminal jurisdiction to punish a murder committed by a Cherokee, against another Cherokee, on Cherokee lands. |
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The opinion is most famous for its ''dicta'', which lays out the relationship between [[Indian tribe|tribes]] and and the [[U.S. state|state]] and [[Federal government of the United States|federal government]]s, building the foundations of the doctrine of [[tribal sovereignty in the United States]].. |
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==The Case== |
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⚫ | [[Georgia (U.S. state)|Georgia]] law required all whites living in Cherokee Indian Territory to obtain a state license. Seven missionaries refused to obey the state law and were arrested, convicted, and sentenced to four years of hard labor |
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==Background== |
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⚫ | The missionaries [[Samuel |
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;Facts |
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⚫ | [[Georgia (U.S. state)|Georgia]] law required all whites living in Cherokee Indian Territory to obtain a state license. Seven missionaries refused to obey the state law and were arrested, convicted, and sentenced to four years of hard labor. They also refused to obey the military when they were asked to leave the state. They appealed their case to the Supreme Court of the United States, arguing that the laws under which they had been convicted were unconstitutional because states have no power or authority to pass laws concerning sovereign Indian Nations. |
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⚫ | The missionaries [[Samuel Worcester]] and Elizur Butler were targeted by Georgia because of their opposition to [[Cherokee removal]]. If they had applied for state licenses, they would have been denied. The Georgia state courts had previously been deferential to Worcester because of his federal appointment as postmaster to [[New Echota]], the Cherokee capital. However, the governor of Georgia, [[George Rockingham Gilmer]], personally persuaded the federal government to withdraw Worcester's appointment as postmaster in order to make him subject to arrest. |
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⚫ | Chief Justice John Marshall laid out in this opinion the relationship between the Indian nations and the United States is that of nations. He argued that the United States, in the character of the federal government, inherited the rights of Great Britain as they were held by that nation. Those rights, he stated, are the sole right of dealing with the Indian nations to the exclusion of any other European power, and not the rights of possession to their land nor political dominion over their laws. He acknowledged that the exercise of conquest and purchase can give political dominion, but those are in the hands of the federal government and not the states. |
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==Opinion== |
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⚫ | Chief Justice[[ John Marshall]] laid out in this opinion the relationship between the Indian nations and the United States is that of nations. He argued that the United States, in the character of the federal government, inherited the rights of Great Britain as they were held by that nation. Those rights, he stated, are the sole right of dealing with the Indian nations to the exclusion of any other European power, and not the rights of possession to their land nor political dominion over their laws. He acknowledged that the exercise of conquest and purchase can give political dominion, but those are in the hands of the federal government and not the states. |
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The court ruled that the Cherokee nation was a "distinct community" with self-government "in which the laws of Georgia can have no force," establishing the doctrine that the national government of the United States, and not individual states, had authority in Indian affairs. |
The court ruled that the Cherokee nation was a "distinct community" with self-government "in which the laws of Georgia can have no force," establishing the doctrine that the national government of the United States, and not individual states, had authority in Indian affairs. |
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==Legacy== |
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== Response to the Decision == |
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===Jackson's response=== |
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In reaction to this decision, President Andrew Jackson has often been quoted as defying the Supreme Court with the words: "John Marshall has made his decision; now let him enforce it!" However, it is disputed whether or not Jackson made any such statement.<ref>{{cite book|last=Boller |first=Paul F. |coauthor=John H. George |title=They Never Said It: A Book of False Quotes, Misquotes, & False Attributions |year=1989 |place=New York, NY |publisher=Oxford University Press |url=http://books.google.com/?id=NCOEYJ0q-DUC&printsec=frontcover |page=53 | isbn=9780195064698}}</ref> (What Jackson may have said was that "the decision of the supreme court has fell still born, and they find that they cannot coerce Georgia to yield to its mandate.") Arguably because of a legal loophole, he had no grounds for becoming involved unless the Georgia courts formally defied the Supreme Court.{{Citation needed|date=August 2010}} That did not happen since Georgia abided by a strict holding of the decision, and pardoned and freed the plaintiff (albeit after several months of shirking the federal judiciary).<ref>Banner, Stuart. ''How the Indians Lost Their Land: Law and Power on the Frontier.'' Cambridge: Harvard UP, 2005.</ref> In doing so, Georgia underscored the reality of ''Worcester'''s true import: despite having no Indian litigants, when the decision was cited as precedent in later Indian decisions, like ''Johnson'' and ''Cherokee Nation'' that preceded it, the case would display an expansive legal impact. Marshall used the decision, at least in part, to vindicate the wrongs he felt he had perpetrated with "[[Johnson v. M'Intosh]]"; Justice Story considered it similarly, writing, in a letter to his wife dated 4 March 1832, "Thanks be to God, the Court can wash their hands clean of the iniquity of oppressing the Indians and disregarding their rights."<ref>Warren, Charles. ''The Supreme Court in United States History.'' 2nd ed. 2 vols. Boston: Little, Brown, 1926. I.757</ref> |
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It is often said that, in response to the decision, President [[Andrew Jackson]], said something to the effect of: "John Marshall has made his decision; now let him enforce it!" More reputable sources recognize this as a false quotation.<ref>{{cite book|last=Boller |first=Paul F. |coauthor=John H. George |title=They Never Said It: A Book of False Quotes, Misquotes, & False Attributions |year=1989 |place=New York, NY |publisher=Oxford University Press |url=http://books.google.com/?id=NCOEYJ0q-DUC&printsec=frontcover |page=53 | isbn=9780195064698}}</ref> |
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In fact, the ruling in ''Worcester'' ordered nothing more than that Worcester be freed; Georgia complied after several months. In 1833, the newly elected governor, [[Wilson Lumpkin]], offered to pardon Worcester and Butler on the condition that they ceased their Cherokee activities; the two complied, and never returned to Cherokee lands (under the authority of a January 14, 1833 general proclamation, not a formal pardon).<ref>Chused, 1999.</ref> The federal government, and the Cherokees, were not party to the suit, and ''Worcester'' imposed no obligations on Jackson; there was nothing for him to enforce.<ref name="b">Banner, 2005, pp. 218--24.</ref><ref>Norgren, 2004, pp. 122--30.</ref> The Court did even ask [[federal marshall]]s to carry out the decision, as had become standard.<ref>Berutti, 1992, pp. 305--06.</ref> ''Worcester'' may be seen as a prudential decision, for avoiding the possibility of political conflict between the Court and the Executive, while still delivering what appeared to be a pro-Indian decision.<ref>Lytle, 1980, p. 69.</ref> |
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Marshall succeeded in ''Worcester'', at least rhetorically, in repudiating some of the "discovery doctrine" put forth in the ''Johnson'' decision, but it was largely too late: though Marshall still presided, Jackson had filled the Court with his own appointees, and the damage was done.<ref>Robertson, Lindsay G. ''Conquest by Law: How the Discovery of America Dispossessed Indigenous Peoples of Their Lands''. Oxford: Oxford UP, 2005.</ref> The removal policy overseen by the second Jackson administration ensured that history would remember Marshall's "Indian Trilogy" no more kindly than it did just the founding ''Johnson'' decision.<ref>Robertson 117-44; Banner 220-7.</ref> Jackson's opponents criticized him for failing to act against Georgia, but even if he had wanted to intervene—and much evidence suggests that he did not, though the President's position is no longer considered in the strictly polar light that it has been in years past<ref>e.g., Banner 221-2. Cf. the entirety of Robert A. Williams' work.</ref>—it is sometimes argued that he lacked legal authority to do so.<ref name="Prucha1984">Prucha (1984), p. 212.</ref> And in any case, any power disparity between Jackson's Executive and Marshall's Judiciary was irrelevant: Georgia abided by the only immediate holding of the case. Having thus complied by releasing the plaintiff, Georgia continued on the course of her Indian policy with little further judicial ado.<ref>Banner 222. Norgren, Jill. ''The Cherokee Cases: Two Landmark Federal Decisions in the Fight for Sovereignty.'' Norman: U of Oklahoma P, 2004. 122-30.</ref> |
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===As a tribal sovereignty precedent=== |
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Perhaps fearing the possibility of a showdown between the Supreme Court and the Executive, and realizing the real likelihood of Jackson refusing to adhere to the Court’s pro-Cherokee decision, the Justices did not follow the standard procedure of requiring federal marshals to carry out the decision, despite Georgia's laxity in pardoning and releasing Worcester.<ref name="Berutti">{{cite journal |last=Berutti |first=Ronald A. |authorlink= |coauthors= |year=1992 |month= |title=The Cherokee Cases: The Fight to Save the Supreme Court and the Cherokee Indians |journal=American Indian Law Review |volume=17 |issue= |pages=291 |id= |url= |accessdate= |quote=}} At pp. 305–306.</ref> In doing so, the Supreme Court implicitly permitted Andrew Jackson not to carry out the decision, thus avoiding the possibility of a political conflict between two branches, while also retaining the pro-Cherokee decision of ''Worcester'' as good precedent for subsequent cases and presidents.<ref name="Lytle1980">{{cite journal |last=Lytle |first=Cliford M. |authorlink= |coauthors= |year=1980 |month= |title=The Supreme Court, Tribal Sovereignty, and Continuing Problems of State Encroachment into Indian Country |journal=American Indian Law Review |volume=8 |issue= |pages=65 |id= |url= |accessdate= |quote=}} At p. 69.</ref> |
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Marshall language in ''Worcester'' may have been motivated by his regret that his earlier opinions in ''Fletcher'' and ''Johnson'' had been used as a justification for Georgia's actions. Justice Story considered it similarly, writing, in a letter to his wife dated March 4, 1832: "Thanks be to God, the Court can wash their hands clean of the iniquity of oppressing the Indians and disregarding their rights."<ref>Warren, 1926, l.757.</ref> In fact, because Jackson proceeded with [[Cherokee removal]], ''Worcester'' was did little more for indigenous rights than ''Johnson'' or ''Cherokee Nation''.<ref>Robertson, 2005, p. 117--44.</ref><ref>Banner, 2005, pp. 220-27.</ref> |
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There can be no question that Jackson, in both his politics and his policy was supportive of Georgia in its efforts to relocate the Cherokees. Despite winning their case in the Supreme Court, Worcester and Butler remained imprisoned until 1833, when a new governor, [[Wilson Lumpkin]], persuaded them to accept [[pardons]] on condition that they would have nothing further to do with the Cherokees. Worcester and Butler were reluctant to accept pardons under such a condition but were eventually pressured to do so by the combined efforts of their lawyers, their missionary organization, and Governor Lumpkin. |
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==Subsequent history== |
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In 1835, a dissident faction of Cherokees signed a removal treaty, the [[Treaty of New Echota]]. Jackson actively lobbied the U.S. Senate to ratify the treaty in 1836, where it passed by a majority of one vote. In 1838, under President [[Martin Van Buren]], this led to the forcible relocation by the U.S. Army of the Cherokees to [[Indian Territory]] (part of present-day Oklahoma) in what would become known as the [[Trail of Tears]]. |
In 1835, a dissident faction of Cherokees signed a removal treaty, the [[Treaty of New Echota]]. Jackson actively lobbied the U.S. Senate to ratify the treaty in 1836, where it passed by a majority of one vote. In 1838, under President [[Martin Van Buren]], this led to the forcible relocation by the U.S. Army of the Cherokees to [[Indian Territory]] (part of present-day Oklahoma) in what would become known as the [[Trail of Tears]]. |
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''Worcester'' is cited in several later opinions on the subject of [[tribal sovereignty in the United States]], including: |
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==Subsequent judicial impact== |
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Marshall's decision set a strong rule that was followed in future judicial opinions. They are |
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⚫ | *''Teague v. Bad River Band'', 236 Wis. 2d 384 (2000) (holding that tribal courts deserve full faith and credit since they are the court of an independent sovereign; however, in order to end confusion, cases that are filed in state and tribal courts require consultation of both courts before they are decided.) |
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==Notes== |
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==See also== |
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* [[List of United States Supreme Court cases, volume 31]] |
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* [[Tribal sovereignty in the United States]] |
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==References== |
==References== |
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*Stuart Banner, ''How the Indians Lost Their Land: Law and Power on the Frontier'' (2005). |
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*{{cite journal |last=Berutti |first=Ronald A. |authorlink= |coauthors= |year=1992 |month= |title=The Cherokee Cases: The Fight to Save the Supreme Court and the Cherokee Indians |journal=American Indian Law Review |volume=17 |issue= |pages=291 |id= |url= |accessdate= |quote=}} |
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==Further reading== |
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*{{cite journal |last=Burke |first=Joseph C. |authorlink= |coauthors= |year=1969 |month= |title=The Cherokee Cases: A Study in Law, Politics, and Morality |journal=Stanford Law Review |volume=21 |issue= 3|pages=500 |doi=10.2307/1227621 |url= http://jstor.org/stable/1227621|accessdate= |quote= |publisher=Stanford Law Review, Vol. 21, No. 3}} |
*{{cite journal |last=Burke |first=Joseph C. |authorlink= |coauthors= |year=1969 |month= |title=The Cherokee Cases: A Study in Law, Politics, and Morality |journal=Stanford Law Review |volume=21 |issue= 3|pages=500 |doi=10.2307/1227621 |url= http://jstor.org/stable/1227621|accessdate= |quote= |publisher=Stanford Law Review, Vol. 21, No. 3}} |
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⚫ | |||
*{{cite journal |last=Lytle |first=Cliford M. |authorlink= |coauthors= |year=1980 |month= |title=The Supreme Court, Tribal Sovereignty, and Continuing Problems of State Encroachment into Indian Country |journal=American Indian Law Review |volume=8 |issue= |pages=65 |id= |url= |accessdate= |quote=}} |
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*Jill Norgren, ''The Cherokee Cases: Two Landmark Federal Decisions in the Fight for Sovereignty'' (2004). |
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*{{cite book |title=The Great Father: The United States Government and the American Indians |last=Prucha |first=Francis Paul |authorlink= |coauthors= |year=1984 |volume=I |publisher=University of Nebraska Press |location=Lincoln |isbn=0803236689 |pages=}} |
*{{cite book |title=The Great Father: The United States Government and the American Indians |last=Prucha |first=Francis Paul |authorlink= |coauthors= |year=1984 |volume=I |publisher=University of Nebraska Press |location=Lincoln |isbn=0803236689 |pages=}} |
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*Lindsay G. Robertson, ''Conquest by Law: How the Discovery of America Dispossessed Indigenous Peoples of Their Lands'' (2005). |
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*{{cite book |title=John Marshall: Definer Of A Nation |last=Smith |first=Jean Edward |authorlink=Jean Edward Smith |coauthors= |year=1996 |publisher=Henry Holt & Company |location=New York |isbn=080501389X |pages=}} |
*{{cite book |title=John Marshall: Definer Of A Nation |last=Smith |first=Jean Edward |authorlink=Jean Edward Smith |coauthors= |year=1996 |publisher=Henry Holt & Company |location=New York |isbn=080501389X |pages=}} |
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*Charles Warren. ''The Supreme Court in United States History,'' (2d. ed., 1926). 2 vols. |
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==External links== |
==External links== |
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{{wikisource}} |
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*{{caselaw source |
*{{caselaw source |
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|case=''Worcester v. Georgia'', 31 U.S. 515 (1832) |
|case=''Worcester v. Georgia'', 31 U.S. 515 (1832) |
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|findlaw=http://laws.findlaw.com/us/31/515.html |
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*[http://www.georgiaencyclopedia.org/nge/Article.jsp?id=h- |
*[http://www.georgiaencyclopedia.org/nge/Article.jsp?id=h-272''Worcester v. Georgia''] in the [[New Georgia Encyclopedia]] |
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{{Native American rights}} |
{{Native American rights}} |
Revision as of 17:22, 24 October 2010
Worcester v. Georgia | |
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Argued February 20, 1832 Decided March 3, 1832 | |
Full case name | Samuel A. Worcester, Plaintiff in Error v. The State of Georgia |
Citations | 31 U.S. 515 (more) 8 L. Ed. 483 |
Case history | |
Prior | Plaintiff convicted in Gwinnett County, Georgia by the Georgia Superior Court (Sept. 15, 1831) |
Subsequent | None |
Holding | |
Worcester's conviction is void, because states have no criminal jurisdiction in Indian Country | |
Court membership | |
| |
Case opinions | |
Majority | Marshall, joined by Johnson, Duvall, Story, Thompson |
Concurrence | McLean |
Dissent | Baldwin |
Laws applied | |
U.S. Const. art. I |
Worcester v. Georgia, 31 U.S. (6 Pet.) 515 (1832), was a case in which the United States Supreme Court vacated the conviction of Samuel Worcester, holding that the state of Georgia had no criminal jurisdiction to punish a murder committed by a Cherokee, against another Cherokee, on Cherokee lands.
The opinion is most famous for its dicta, which lays out the relationship between tribes and and the state and federal governments, building the foundations of the doctrine of tribal sovereignty in the United States..
Background
- Facts
Georgia law required all whites living in Cherokee Indian Territory to obtain a state license. Seven missionaries refused to obey the state law and were arrested, convicted, and sentenced to four years of hard labor. They also refused to obey the military when they were asked to leave the state. They appealed their case to the Supreme Court of the United States, arguing that the laws under which they had been convicted were unconstitutional because states have no power or authority to pass laws concerning sovereign Indian Nations.
The missionaries Samuel Worcester and Elizur Butler were targeted by Georgia because of their opposition to Cherokee removal. If they had applied for state licenses, they would have been denied. The Georgia state courts had previously been deferential to Worcester because of his federal appointment as postmaster to New Echota, the Cherokee capital. However, the governor of Georgia, George Rockingham Gilmer, personally persuaded the federal government to withdraw Worcester's appointment as postmaster in order to make him subject to arrest.
Opinion
Chief JusticeJohn Marshall laid out in this opinion the relationship between the Indian nations and the United States is that of nations. He argued that the United States, in the character of the federal government, inherited the rights of Great Britain as they were held by that nation. Those rights, he stated, are the sole right of dealing with the Indian nations to the exclusion of any other European power, and not the rights of possession to their land nor political dominion over their laws. He acknowledged that the exercise of conquest and purchase can give political dominion, but those are in the hands of the federal government and not the states.
The court ruled that the Cherokee nation was a "distinct community" with self-government "in which the laws of Georgia can have no force," establishing the doctrine that the national government of the United States, and not individual states, had authority in Indian affairs.
Legacy
Jackson's response
It is often said that, in response to the decision, President Andrew Jackson, said something to the effect of: "John Marshall has made his decision; now let him enforce it!" More reputable sources recognize this as a false quotation.[1]
In fact, the ruling in Worcester ordered nothing more than that Worcester be freed; Georgia complied after several months. In 1833, the newly elected governor, Wilson Lumpkin, offered to pardon Worcester and Butler on the condition that they ceased their Cherokee activities; the two complied, and never returned to Cherokee lands (under the authority of a January 14, 1833 general proclamation, not a formal pardon).[2] The federal government, and the Cherokees, were not party to the suit, and Worcester imposed no obligations on Jackson; there was nothing for him to enforce.[3][4] The Court did even ask federal marshalls to carry out the decision, as had become standard.[5] Worcester may be seen as a prudential decision, for avoiding the possibility of political conflict between the Court and the Executive, while still delivering what appeared to be a pro-Indian decision.[6]
As a tribal sovereignty precedent
Marshall language in Worcester may have been motivated by his regret that his earlier opinions in Fletcher and Johnson had been used as a justification for Georgia's actions. Justice Story considered it similarly, writing, in a letter to his wife dated March 4, 1832: "Thanks be to God, the Court can wash their hands clean of the iniquity of oppressing the Indians and disregarding their rights."[7] In fact, because Jackson proceeded with Cherokee removal, Worcester was did little more for indigenous rights than Johnson or Cherokee Nation.[8][9]
In 1835, a dissident faction of Cherokees signed a removal treaty, the Treaty of New Echota. Jackson actively lobbied the U.S. Senate to ratify the treaty in 1836, where it passed by a majority of one vote. In 1838, under President Martin Van Buren, this led to the forcible relocation by the U.S. Army of the Cherokees to Indian Territory (part of present-day Oklahoma) in what would become known as the Trail of Tears.
Worcester is cited in several later opinions on the subject of tribal sovereignty in the United States, including:
- United States v. Holiday, 70 U.S. 407 (1866) (holding that a Congressional ban on selling liquor to the Indians was Constitutional)
- In re Heff, 197 U.S. 488 (1905) (holding that Congress has the power to place the Indians under state law if it chooses, and the ban on selling liquor does not apply to Indians subject to the Allotment acts)
- Iron Crow v. Ogallala Sioux Tribe, 129 F. Supp. 15 (1955) (holding that tribes have power to create and change their court system and that power is limited only by Congress, not the courts)
- Wisconsin Potowatomies of Hannahville Indian Community v. Houston, 393 F. Supp. 719 (holding that tribal law and not state law governs the custody of children domiciled on reservation land)
- Merrion v. Jicarilla Apache Tribe, 455 U.S. 130 (1982) (holding that Indian Nations have the power to tax Non-Native Americans based on their power as a nation and treaty rights to exclude others; this right can be curtailed only by Congress.)
- American Indian Agricultural Credit Consortium, Inc. v. Fredericks, 551 F. Supp. 1020 (1982) (holding that federal, not state courts have jurisdiction over tribal members)
- Maynard v. Narrangansett Indian Tribe, 798 F. Supp. 94 (1992) (holding that tribes have sovereign immunity against state tort claims)
- Venetie I.R.A. Council v. Alaska, 798 F. Supp. 94 (holding that tribes have power to recognize and legislate adoptions)
- Native American Church v. Navajo Tribal Council, 272 F.2d 131 (holding that the First Amendment does not apply to Indian nations unless it is applied by Congress)
- Teague v. Bad River Band, 236 Wis. 2d 384 (2000) (holding that tribal courts deserve full faith and credit since they are the court of an independent sovereign; however, in order to end confusion, cases that are filed in state and tribal courts require consultation of both courts before they are decided.)
- Inyo County v. Paiute-Shoshone Indians (U.S. 2003) (holding that tribal sovereign power precludes the right to private property and against search and seizure by the state)
Notes
- ^ Boller, Paul F. (1989). They Never Said It: A Book of False Quotes, Misquotes, & False Attributions. New York, NY: Oxford University Press. p. 53. ISBN 9780195064698.
{{cite book}}
: Unknown parameter|coauthor=
ignored (|author=
suggested) (help) - ^ Chused, 1999.
- ^ Banner, 2005, pp. 218--24.
- ^ Norgren, 2004, pp. 122--30.
- ^ Berutti, 1992, pp. 305--06.
- ^ Lytle, 1980, p. 69.
- ^ Warren, 1926, l.757.
- ^ Robertson, 2005, p. 117--44.
- ^ Banner, 2005, pp. 220-27.
References
- Stuart Banner, How the Indians Lost Their Land: Law and Power on the Frontier (2005).
- Berutti, Ronald A. (1992). "The Cherokee Cases: The Fight to Save the Supreme Court and the Cherokee Indians". American Indian Law Review. 17: 291.
{{cite journal}}
: Cite has empty unknown parameters:|month=
and|coauthors=
(help) - Burke, Joseph C. (1969). "The Cherokee Cases: A Study in Law, Politics, and Morality". Stanford Law Review. 21 (3). Stanford Law Review, Vol. 21, No. 3: 500. doi:10.2307/1227621.
{{cite journal}}
: Cite has empty unknown parameters:|month=
and|coauthors=
(help) - Chused, Richard (1999). Cases, Materials, and Problems in Property (2nd ed.). New York: M. Bender. ISBN 0820541354.
{{cite book}}
: Cite has empty unknown parameter:|coauthors=
(help) - Lytle, Cliford M. (1980). "The Supreme Court, Tribal Sovereignty, and Continuing Problems of State Encroachment into Indian Country". American Indian Law Review. 8: 65.
{{cite journal}}
: Cite has empty unknown parameters:|month=
and|coauthors=
(help) - Jill Norgren, The Cherokee Cases: Two Landmark Federal Decisions in the Fight for Sovereignty (2004).
- Prucha, Francis Paul (1984). The Great Father: The United States Government and the American Indians. Vol. I. Lincoln: University of Nebraska Press. ISBN 0803236689.
{{cite book}}
: Cite has empty unknown parameter:|coauthors=
(help) - Lindsay G. Robertson, Conquest by Law: How the Discovery of America Dispossessed Indigenous Peoples of Their Lands (2005).
- Smith, Jean Edward (1996). John Marshall: Definer Of A Nation. New York: Henry Holt & Company. ISBN 080501389X.
{{cite book}}
: Cite has empty unknown parameter:|coauthors=
(help) - Charles Warren. The Supreme Court in United States History, (2d. ed., 1926). 2 vols.
External links
- Text of Worcester v. Georgia, 31 U.S. 515 (1832) is available from: Findlaw Justia
- Worcester v. Georgia in the New Georgia Encyclopedia