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Henkel v. U.S., 196 F. 345, 116 C.C.A. 165

Facts

The United States initiated legal action to reclaim about 800 acres of land on the Blackfeet Indian reservation, which was necessary for the Milk River irrigation project. Prior to the action, the Henkel family, consisting of both Indian and non-Indian members, had occupied the land and made a written proposition to relinquish their claims in exchange for $7,500. This proposition was approved by the Secretary of the Interior, and the family signed a receipt and relinquishment of their rights. The defendants later contested the validity of the relinquishment, arguing lack of capacity and jurisdiction.

The complaint alleged that prior to November 5, 1906, the United States, pursuant to the Reclamation Act (Act June 17, 1902, c. 1093, 32 Stat. 388 (U.S. Comp. St. Supp. 1911, p. 662)), made surveys for the Milk river irrigation project, in the northern part of Montana, and that the lands described in the complaint were necessary for flowage and construction purposes in connection with said project.

Issue

The main legal issues were whether the Henkel family's relinquishment of their land rights was valid and whether the government had the authority to acquire land within an Indian reservation for reclamation purposes.

It is contended that the instruments signed by and on behalf of the plaintiffs in error are void for want of capacity on their part to make such disposition of their right to select the lands in controversy as their allotments, and for want of capacity on the part of the officers of the government, charged with the execution of the reclamation law, to acquire such lands or any lands within an Indian reservation, or to devote any of such lands to reclamation purposes.

Rule

The court applied principles regarding the capacity of Indian tribes to relinquish land rights and the authority of the United States government to acquire land for public projects under the Reclamation Act.

By the agreement between the United States and the Blackfeet Indians of September 26, 1895 (29 Stat. 355), it was provided in article 5 that during the existence of the agreement no allotments of land in severalty should be made to the Indians, but that the whole reservation should be considered to be held by them as a communal grazing tract.

Analysis

The court determined that the Henkel family, as members of the Piegan tribe and wards of the government, had the capacity to relinquish their preference rights to the land. It noted that the relinquishment was valid as it was made to the United States, which holds ultimate title to the lands. The court also found that the government officials acted within their authority in accepting the relinquishment and compensating the family.

The plaintiffs in error did not relinquish their allotment right, but merely their preference right to select for their allotment the particular tract of land on which they resided.

Conclusion

The court affirmed the lower court's judgment, ruling that the United States was entitled to reclaim the land as the relinquishments made by the Henkel family were valid and enforceable.

We find no error. The judgment is affirmed.

Who won?

The United States prevailed in the case because the court upheld the validity of the relinquishments made by the Henkel family and confirmed the government's authority to acquire the land for reclamation purposes.

The court found that the officers of the United States who conducted the negotiations and received the relinquishment and paid for the same acted within the scope of their authority.

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