Introduction

In the landmark case of Janet L. Yellen, Secretary of the Treasury, Petitioner v. Confederated Tribes of the Chehalis Reservation, et al., the Supreme Court of the United States addressed a critical question regarding the eligibility of Alaska Native Corporations (ANCs) for federal relief under the Coronavirus Aid, Relief, and Economic Security (CARES) Act. Central to the dispute was whether ANCs qualify as "Indian tribes" under the Indian Self-Determination and Education Assistance Act (ISDA), thereby making them eligible to receive a portion of the $8 billion allocated to "Tribal governments" for compensating unbudgeted expenditures due to COVID-19.

The plaintiffs, federally recognized tribes, contended that only federally recognized tribes—which maintain a government-to-government relationship with the United States—should be eligible for these funds. Conversely, the ANCs and the Department of the Treasury argued that ANCs fall within the statutory definition of "Indian tribes" under ISDA, despite not being federally recognized tribes.

Summary of the Judgment

The Supreme Court, in an opinion delivered by Justice Sotomayor, reversed the decision of the Court of Appeals for the District of Columbia Circuit. The Court held that ANCs are indeed "Indian tribes" under ISDA. Consequently, ANCs are eligible for funding under Title V of the CARES Act. This decision aligns with the Department of the Interior's longstanding interpretation that ANCs qualify as Indian tribes within the context of ISDA.

Analysis

Precedents Cited

The Court referenced several prior cases that elucidate the unique status of Alaska Natives. Notably, cases like Sturgeon v. Frost and ALASKA v. NATIVE VILLAGE OF VENETIE TRIBAL GOVERNMENT highlight the distinct historical and legal relationship between Alaska Natives and the United States. These cases underscore that Alaska's indigenous entities often serve as exceptions to general federal Indian law principles applicable in the lower 48 states.

Legal Reasoning

The Court primarily focused on the plain meaning of the statutory language within ISDA. ISDA's definition of an "Indian tribe" explicitly includes "any Alaska Native village or regional or village corporation as defined in or established pursuant to the Alaska Native Claims Settlement Act (ANCSA)." The Court determined that ANCs are eligible for ISDA's benefits, which satisfies the "recognized as eligible" clause in the statutory definition. This interpretation aligns with the Department of the Interior's consistent position over decades.

The dissenting opinion, led by Justice Gorsuch, argued for a term-of-art construction equating "recognized as eligible" solely with federally recognized tribes. However, the majority found this approach unpersuasive, emphasizing that such a reading would undermine the explicit inclusion of ANCs in the statutory definition.

Impact

This judgment has far-reaching implications for Alaska Native Corporations and potentially other entities under similar statutes. By affirming the eligibility of ANCs for CARES Act funding, the Court reinforces the federal government's recognition of ANCs as integral components of Alaska's indigenous governance framework. This decision may influence eligibility criteria in other federal programs that reference ISDA's definition of "Indian tribes," ensuring that uniquely structured entities like ANCs receive appropriate federal support.

Complex Concepts Simplified

Conclusion

The Supreme Court's affirmation that Alaska Native Corporations are "Indian tribes" under ISDA marks a significant development in federal Indian law. By recognizing ANCs as eligible entities for CARES Act funding, the Court has validated the unique model established by ANCSA, which balances corporate structures with indigenous governance. This decision not only provides immediate financial relief to Alaska Natives through ANCs but also sets a precedent for the interpretation of statutory definitions concerning tribal eligibility in future legislation. The ruling underscores the importance of context and statutory intent in legal interpretations, ensuring that specialized entities like ANCs are appropriately acknowledged within the framework of federal support and recognition.