Williams v. Lee

Brief Fact Summary.

A Navajo couple living on a Navajo Reservation fail to pay their credit bills stemming from a store located on the Reservation and are sued in state court. The Supreme Court denies the state court jurisdiction because the dispute arose on the Navajo Reservation and because the state did not grant benefits to the Reservation in a way that would make it proper for them to exercise jurisdiction.

Synopsis of Rule of Law.

A state does not have power to enforce its laws within the Reservation if it is not providing the Reservation with services.

Facts.

Plaintiff Lee, not a Navajo, operated a store under a federal license on a Navajo Reservation in Arizona where Plaintiff Williams and his wife, both Navajos, purchased goods on credit. An 1868 treaty reserved the Navajo Reservation for use solely by Najavo people. Lee sued Williams for non payment in Arizona state court.

Issue.

Do state courts have jurisdiction over disputes arising on Native American Reservations?

Held.

No, state courts do not have jurisdiction over disputes arising on Native American Reservations unless the state also provides other services to the Native Americans living on the Reservation. The ruling of the Supreme Court of Arizona reversed.

Discussion.

1. A state cannot infringe on a Reservation’s sovereignty unless it is willing to provide the same services to the Reservation that it provides to other citizens of the state.
2. The Navajo Nation has been independent for almost a century and has its own tribal courts and government system.
3. Arizona has not provided services to the Navajo Reservation and thus cannot interfere with the Reservation’s right to govern its own disputes.
4. Therefore the ruling of the Arizona Supreme Court is reversed.