Match-E-Be-Nash-She-Wish Band v. Patchak (2011)
- Docket
- 11-246
- Decided
- 2011-01-01
Summary
Question: 1. Does Patchak lack standing because he does not fall within the zone-of-interests protected by the Indian Reorganization Act? 2. Is Patchak's suit precluded by sovereign immunity to quiet title claims drawn from the Quiet Title Act? Conclusion: No, No. Justice Elena Kagan, writing for an 8-1 majority, affirmed the lower court. The Court held that the US had waived its sovereign immunity and Patchak had proper standing to bring suit. While the government claimed that the QTA barred Patchak's relief under the Administrative Procedure Act ("APA"), the Court held that the QTA only concerns individuals claiming a personal interest contrary to the government's interest in a property. Since Patchak's suit did not resemble a typical quiet title suit, the sovereign immunity waiver under the APA still applies. The Court further concluded that Patchak had standing to bring the suit because his claim falls within the zone-of-interests that the IRA regulates. The zone-of-interests standard is not intended to be particularly demanding, and merely requires a recognizable relation to the acquisition or use of territory for Indian tribes. Since Patchak's suit arguably concerns the acquisition and use of such territory, he has sufficient standing to proceed. Justice Sonia Sotomayor was the sole dissenter. She expressed dissatisfaction with the majority's broad stroke limitation on sovereign immunity under the QTA. Under the majority's formulation, those with no personal interest in government owned property could bypass sovereign immunity to challenge the government's interest.