Parties Involved: Julia Martinez, Santa Clara Pueblo Tribe, and its Governor
Court: U.S. Supreme Court
Background
Plaintiff: Julia Martinez, a full-blooded member of the Santa Clara Pueblo tribe.
Issue: Denial of membership to children of female tribe members married outside the tribe, while children of male members married outside were granted membership.
Location: New Mexico Federal Court
Legal Basis
Ordinance Challenge: Martinez argued the ordinance discriminated based on sex and ancestry.
Indian Civil Rights Act of 1968
Key provision: "No Indian tribe in exercising powers of self-government shall... deny to any person within its jurisdiction the equal protection of its laws."
14th Amendment: Invoked the equal protection clause of the U.S. Constitution.
Court Proceedings
Initial Court: Case presented in New Mexico federal court.
Final Ruling: U.S. Supreme Court.
Supreme Court Ruling
Decision: 7-1 in favor of Santa Clara Pueblo.
Sovereignty: Acknowledged the tribal sovereignty of the Santa Clara Pueblo tribe.
Historical Context: Tribe’s existence predates the U.S. Constitution.
Membership Rights: Tribe has the power to decide its membership.
Congressional Abrogation: No abrogation by Congress under the Indian Civil Rights Act of 1968 regarding membership or sovereign immunity.
Injunctive Relief: Suit could not be heard in federal court due to sovereign immunity under the 11th Amendment.
Implications
Tribal Sovereignty: Reinforced the autonomy of Native American tribes in deciding membership rules.
Legal Precedent: Established precedent for interpreting tribal sovereignty and limitations on federal court jurisdiction over tribal decisions.