Supreme Court Cases

 

Arizona v. Navajo Nation

Docket: 21-1484 Decision Date: 2023-06-22
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This links to the official slip opinion PDF.
How to read this page

Below are plain-language sections to help you understand what the Court decided in Arizona v. Navajo Nation and why it matters. Quotes are taken from the syllabus (the Court’s short summary at the start of the opinion).

Summary

A short, plain-English overview of Arizona v. Navajo Nation.

The Supreme Court reviewed whether the 1868 treaty between the United States and the Navajo Nation required the federal government to take affirmative steps to secure water for the tribe. The Court reversed the Ninth Circuit's decision, concluding that the treaty did not impose such a duty on the United States. The case involved the Navajo Nation's claim that the federal government had not fulfilled its trust obligations under the treaty.

Holding

The single most important “bottom line” of what the Court decided in Arizona v. Navajo Nation.

The Court held that the 1868 treaty did not require the United States to take affirmative steps to secure water for the Navajo Nation.

Constitutional Concepts

These are the Constitution-related themes that appear in Arizona v. Navajo Nation. Click a concept to see other cases that involve the same idea.

  • Why State–Federal Power is relevant to Arizona v. Navajo Nation

    The case involves the allocation of authority between state and federal governments regarding water rights and the obligations of the federal government under a treaty with an Indian tribe.

    Syllabus excerpt (verbatim)
    The States of Arizona, Nevada, and Colorado intervened against the Tribe to protect those States' interests in water from the Colorado River.
  • Why Judicial Review is relevant to Arizona v. Navajo Nation

    The Court reviews the obligations of the federal government under the 1868 treaty and whether it imposes a duty to secure water for the Navajo Nation.

    Syllabus excerpt (verbatim)
    The Tribe asserts a breach-of-trust claim based on its view that the 1868 treaty imposed a duty on the United States to take affirmative steps to secure water for the Navajos.
  • Why Remedies and Relief is relevant to Arizona v. Navajo Nation

    The case addresses the scope of remedies the Navajo Nation seeks, specifically whether the United States must take affirmative steps to secure water.

    Syllabus excerpt (verbatim)
    The Navajos fled suit seeking to compel the United States to take affirmative steps to secure needed water for the Tribe.

Key Quotes

Short excerpts from the syllabus in Arizona v. Navajo Nation that support the summary and concepts above.

  • The 1868 treaty establishing the Navajo Reservation reserved necessary water to accomplish the purpose of the Navajo Reservation but did not require the United States to take affirmative steps to secure water for the Tribe.
  • Indian treaties cannot be rewritten or expanded beyond their clear terms.
  • The Federal Government's liability on a breach-of-trust claim cannot be premised on control alone.

 

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