Williams v. Lee

Brief Fact Summary.

Williams appealed a state court judgment that determined that a state court, rather than a tribal court, maintained jurisdiction over a dispute arising out of a Native American reservation.

Synopsis of Rule of Law.

State courts do not have jurisdiction over disputes on Native American reservations unless the state is providing services to that reservation.

Facts.

Williams and his wife purchased goods on credit from a store operated by Lee on a Native American reservation. Lee operated the store through a federal license although he was not Native American. Lee sued Williams for nonpayment and Williams sought to dismiss because the proper court was tribal court. The court denied Lee’s motion and granted judgment to Lee. The Supreme Court of Arizona affirmed and Williams appealed.

Issue.

Whether state courts have jurisdiction over disputes on Native American Reservations?

Held.

No. The judgment of the Supreme Court of Arizona is reversed because the state courts did not have jurisdiction over the case. Arizona has not taken the responsibility to provide alternative services to the reservation, and therefore cannot interfere with the tribe’s right to govern it’s own affairs.

Discussion.

A state may not interfere with a Native American reservation’s ability to govern itself unless the state is prepared to provide services such as welfare and education to the reservation as well.