Round Valley Indian Tribes v. United States
97 Fed. Cl. 500
Fed. Cl.2011Background
- Round Valley Tribes (Yuki, Concow Maidu, Little Lake, Pomo, Nomlaki, Cahto, Wailaki, Pit River) have historical trust fund claims against the United States.
- ICC Act of 1946 established the Indian Claims Commission to adjudicate tribal claims and a five-year filing window, with Section 12 barring pre-August 13, 1946 claims not presented by August 13, 1951.
- In 1964 the ICC issued a Final Determination in Thompson and Risling representing Indians of California (the identifiable group) and paid $29,100,000; later funds were deposited for the Indians of California.
- Congress enacted ITFMA (1994) and, later, Reconciliation Report Act (2002) addressing trust fund reconciliations and deeming receipt dates as of December 31, 1999 for accrual purposes.
- In 2006 the Tribes filed a Complaint in the U.S. Court of Federal Claims alleging breach of fiduciary duties in trust fund management from 1855 to present; the Government moved for partial summary judgment on pre-July 20, 1964 claims.
- The court denied the Government’s motion, ruling Tribes may pursue breach of trust claims accruing after 1946, including those pre-dating 1964."
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether pre-1964 breach claims are precluded | Tribes were not in privity or bound by earlier Indians of California actions | Trib es were represented by Indians of California petitions; preclusion applies | Not barred; preclusion does not apply to the Tribes' pre-1964 claims |
| Whether waiver/release bars Tribes’ pre-1964 claims | Trib es not parties to stipulations; not bound | Stipulations released all claims by petitioners and claimants | Not waived; Tribes not bound by prior stipulations |
| Whether ICCA Section 12 bars pre-1946 claims | Claims accrued in 1999; Section 12 does not bar | Section 12 is a repose bar; all pre-1946 claims barred | Section 12 does not bar claims accruing after 1946; Tribes' claims accrue in 1999 |
| Accrual and impact of Reconciliation/ITFMA provisions | ITFMA and 2002 Act fix accrual as of 1999 | Even with ITFMA, ICCA bar pre-1946 claims | Accrual date is December 31, 1999; Section 12 does not bar |
Key Cases Cited
- Federated Department Stores, Inc. v. Moitie, 452 U.S. 394 (U.S. 1981) (final judgments can preclude relitigation of issues)
- Parklane Hosiery Co. v. Shore, 439 U.S. 322 (U.S. 1979) (three-part test for claim preclusion (identity of parties, final judgment on merits, same transaction))
- Navajo Nation v. United States, 537 U.S. 488 (U.S. 2003) (trust duties and fiduciary obligations establish jurisdiction under Indian Tucker Act)
- United States v. Mitchell, 463 U.S. 206 (U.S. 1983) (fiduciary duties and trust relationship underpin Government liability)
- Hallco Mfg. Co., Inc. v. Foster, 256 F.3d 1290 (Fed. Cir. 2001) (consent judgments have same effect as judgments on the merits for res judicata)
- Thompson I, 122 Ct.Cl. 348 (Ct. Cl. 1952) (identifiable group concept under ICCA; Indians of California scope)
- Shoshone Indian Tribe of Wind River Reservation v. United States, 364 F.3d 1339 (Fed. Cir. 2004) (Appropriations Provisos toll accrual until accounting; accrual date relevance)
- Osage Nation v. United States, 57 F.3d 392 (F.3d 1993) (reconciliation/reporting and accrual mechanics discussed)
- Acumed LLC v. Stryker Corp., 525 F.3d 1319 (Fed. Cir. 2008) (definition of transactional facts for claim consolidation)
- Vitaline Corp. v. General Mills, Inc., 891 F.2d 275 (Fed. Cir. 1989) (concept of same transactional facts for preclusion)