United States v. Sandoval, 231 U.S. 28 (1913) (No. 352)

Case name: United States v. Sandoval Opinion filed: 1913-10-20 Docket No.: 352 Citations: • 231 U.S. 28 • 34 S. Ct. 1 • 58 L. Ed. 107 • 1913 U.S. LEXIS 2638 Case holding summaries: • explaining that Congress recognized the Pueblos’ title to their lands by statute and that executive orders reserved additional public lands • describing the lands in question as “held in communal, fee simple ownership under grants from the King of Spain, made during the Spanish sovereignty, and confirmed by Congress since the acquisition of [the New Mexico] territory by the United States.” • holding that Pueblo lands were Indian country when Congress had confirmed the land grants made to the Pueblo Indians by the King of Spain and that adjacent lands had been “reserved by Executive orders for the use and occupancy of the Indians” (emphasis added) • finding that Congress could restrict the alienation of land that New Mexico Pueblo Indians held in fee simple • finding that Congress could restrict the alienation of land that New Mexico Pueblo Indians held in fee simple • finding that Congress could restrict the alienation of land that New Mexico Pueblo Indians held in fee simple • rejecting position that Indian lands held in fee simple by Pueblo cannot be Indian country • explaining that the "questions whether, to what extent, and for what time [Indian groups] shall be recognized and dealt with as dependent tribes requiring the guardianship and protection of the United States are to be determined by Congress, and not by the courts." • recognition of Indian tribes is also left to the political branches • describing the lands in question as 16 “held in communal, fee simple ownership under grants from the King of Spain, made 17 during the Spanish sovereignty, and confirmed by Congress since the acquisition of 18 [the New Mexico] territory by the United States.” • rejecting the argument that Pueblo Indians holding fee simple title to lands precludes the lands from being Indian country