Sault Ste. Marie Tribe of Chippewa Indians v. Haaland, No. 20-5123 (D.C. Cir. 2022)
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The Sault Ste. Marie Tribe of Chippewa Indians purchased the Sibley Parcel with interest from its Self-Sufficiency Fund and sought to have the land taken into trust by the Department of the Interior with a view to establishing gaming operations. The Tribe claimed the Parcel was acquired for the “enhancement of tribal lands,” a permitted use of Fund interest under the Michigan Indian Land Claims Settlement Act Section 108(c). Interior concluded that the mere acquisition of additional land was not an “enhancement” and declined to take the Parcel into trust because the Tribe failed to demonstrate how the Parcel would improve or enhance tribal lands. The land is in Michigan’s Lower Peninsula far from the Tribe’s existing lands in the Upper Peninsula.
The district court granted summary judgment to the Tribe. The D.C. Circuit reversed. Under the plain meaning of the Michigan Act, before assuming a trust obligation, The Department has the authority to verify that the Tribe properly acquired the land with Fund interest, consistent with the limited uses for such interest in Section 108(c). In exercising that authority, The Department correctly determined that “enhancement of tribal lands” does not include an acquisition that merely increases the Tribe’s landholdings. To enhance tribal lands, an acquisition must improve the quality or value of the Tribe’s existing lands.
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