Haaland v. Brackeen
View Official PDFBelow are plain-language sections to help you understand what the Court decided in Haaland v. Brackeen 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 Haaland v. Brackeen.
The Supreme Court reviewed the constitutionality of the Indian Child Welfare Act (ICWA), which governs child custody proceedings involving Indian children. The Court addressed challenges related to Congress's authority under the Indian Commerce Clause, the Tenth Amendment's anticommandeering principle, and standing issues. The Court upheld ICWA's consistency with Congress's legislative power and rejected anticommandeering challenges but did not address equal protection and nondelegation claims due to lack of standing.
Holding
The single most important “bottom line” of what the Court decided in Haaland v. Brackeen.
The Court held that ICWA is consistent with Congress's Article I authority and rejected anticommandeering challenges to its provisions.
Constitutional Concepts
These are the Constitution-related themes that appear in Haaland v. Brackeen. Click a concept to see other cases that involve the same idea.
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Why State–Federal Power is relevant to Haaland v. Brackeen
The case primarily involves the allocation of authority between state and federal governments, particularly regarding the application of the Indian Child Welfare Act.
Syllabus excerpt (verbatim)Petitioners challenged ICWA as unconstitutional on multiple grounds. They asserted that Congress lacks authority to enact ICWA and that several of ICWA's requirements violate the anticommandeering principle of the Tenth Amendment.
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Why Standing is relevant to Haaland v. Brackeen
The Court addresses whether the parties have standing to bring certain constitutional claims, including equal protection and nondelegation challenges.
Syllabus excerpt (verbatim)The Court does not reach the merits of petitioners' two additional claims—an equal protection challenge to ICWA's placement preferences and a nondelegation challenge to § 1915(c), the provision allowing tribes to alter the placement preferences—because no party before the Court has standing to raise them.
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Why Commerce Clause is relevant to Haaland v. Brackeen
The Court discusses Congress's power under the Indian Commerce Clause as a basis for enacting ICWA.
Syllabus excerpt (verbatim)The Indian Commerce Clause authorizes Congress '[t]o regulate Commerce . . . with the Indian Tribes,' U. S. Const., Art. I, § 8, cl. 3, and the Court has interpreted the Indian Commerce Clause to reach not only trade, but also certain 'Indian affairs.'
Key Quotes
Short excerpts from the syllabus in Haaland v. Brackeen that support the summary and concepts above.
ICWA governs state-court adoption and foster care proceedings involving Indian children.
Congress's power to legislate with respect to Indians is well established and broad, but it is not unbounded.
The Court declines to disturb the Fifth Circuit's conclusion that ICWA is consistent with Congress's Article I authority.
