Sunday, November 24, 2013

Williams v. Lee case brief

Williams v. Lee case brief summary
358 U.S. 217 (1959)

Respondent merchant filed a collection action against petitioners, Native American customers, for goods sold on credit at a store located on the Navajo Indian Reservation. The Supreme Court of Arizona affirmed the trial court's judgment that the state courts had jurisdiction. Petitioners sought review.

A non-Native American merchant ran a general store on a Navajo reservation.


  • The court found that the Arizona state court improperly exercised jurisdiction of a collection action filed by the merchant against the Native American customers. 
  • The court held that states have no power to regulate the affairs of Native Americans on a reservation. 
  • The court found that the Navajo Courts of Indian Offenses exercised broad criminal and civil jurisdiction that covered suits by outsiders against Native American defendants. 
  • Federal law granted states the power to assume jurisdiction over reservation matters if the state legislature or the people affirmatively accepted the responsibility. 
  • The court found that Arizona expressly disclaimed such jurisdiction. 
  • The court held that the Navajo Treaty of 1868 controlled and civil jurisdiction resided with the reservation's courts.
The judgment was reversed so that the tribal courts could properly exercise authority over a reservation matter pursuant to a treaty.

Recommended Supplements for Civil Procedure

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