Yellen v. Confederated Tribes of the Chehalis Reservation
Overview
Overview
The Supreme Court held that Alaska Native Corporations are 'Indian tribes' eligible to receive CARES Act funding set aside for tribal governments, resolving a dispute over whether corporations created by statute to serve Alaska Natives qualify for programs designed for tribal governments.
The Facts
Facts
The CARES Act set aside $8 billion for 'Indian Tribes.' The Indian Self-Determination Act defines tribes to include ANCs. Non-ANC tribes sued to exclude ANCs from the relief fund, arguing ANCs are not governments and should not share in government-to-government funding.
The Issue
Issue
Whether Alaska Native Corporations are 'Indian tribe[s]' under the Indian Self-Determination and Education Assistance Act and thus eligible for CARES Act funds set aside for tribal governments.
The Rules
Rule
The ISDEAA defines 'Indian tribe' to include 'any Alaska Native village or regional or village corporation as defined in or established pursuant to the Alaska Native Claims Settlement Act.' ANCs are defined within ANCSA. The ISDEAA's definition therefore includes ANCs, making them eligible for any program that uses the ISDEAA definition of Indian tribe.
The Application
Analysis
The CARES Act incorporated the ISDEAA definition of "Indian tribe," which explicitly includes Alaska Native Corporations created under the Alaska Native Claims Settlement Act. Applying that statutory definition, ANCs qualified for the $8 billion relief fund despite operating as corporations rather than traditional governments. The non-ANC tribes' challenge failed because the statutory definition, not the recipient's organizational form, controls who counts as an "Indian tribe" for federal appropriations purposes.
The Conclusion
Conclusion
Court held 6-3 that ANCs qualify as Indian tribes under the ISDA definition incorporated by the CARES Act. Justice Sotomayor wrote for the majority.
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