Overview
The Supreme Court case Johnson & Graham's Lessee v. McIntosh (1823) addressed whether Native American tribes could legally convey land to individuals, concluding that only the federal government had such authority.
Background and Facts
- In 1775, Johnson and others bought land in Virginia from the Piankeshaw tribe under the King's proclamation.
- Johnson's heirs inherited this land after his death.
- In 1818, M'Intosh purchased the same land area from Congress.
- Johnson's heirs sued M'Intosh to reclaim the land, but the district court favored M'Intosh, finding the Indian sale invalid.
Legal Question
- The core legal question was whether a Native American tribe could legally convey land title to private individuals.
Supreme Court Decision and Reasoning
- The Court unanimously held that M'Intosh's claim, derived from Congress, was superior.
- Chief Justice Marshall ruled that only the federal government could negotiate with Native American nations for land transactions.
- Native tribes did not have the right under U.S. law to sell land directly to individuals.
Impact and Precedent
- The decision established that land title transfers from Native Americans to private parties were invalid unless made by or through the federal government.
- This precedent reinforced federal authority over Native land transactions.
Decisions
- Only the federal government may convey Native American land rights to private individuals.
- M'Intosh's claim through Congressional purchase was valid; Johnson's heirs' claim via tribal purchase was invalid.