Patchak v. Zinke

Supreme Court of the United States · 2018 · Federal Courts

Federal CourtsArticle IIIJurisdiction StrippingSeparation of PowersArticle IIIjudicial powerlegislative powerjurisdiction stripping

Facts

Patchak challenged the Secretary of the Interior's decision to take the Bradley Property into trust for the Match-E-Be-Nash-She-Wish Band of Pottawatomi Indians. In Patchak I, the Supreme Court held that the Secretary lacked sovereign immunity and that Patchak's suit could proceed. While the case was back in District Court, Congress enacted the Gun Lake Act, which reaffirmed the Bradley Property as trust land and provided that any federal action, including pending actions, relating to that land shall not be filed or maintained in federal court and shall be promptly dismissed. The District Court then dismissed Patchak's suit based on §2(b).

Issue

Does §2(b) of the Gun Lake Act, which requires dismissal of federal actions relating to the Bradley Property, violate Article III by impermissibly exercising the judicial power rather than the legislative power?

Rule

Congress violates Article III when it compels findings or results under old law, but it does not violate Article III when it changes the law. A statute that strips federal courts of jurisdiction over a class of cases changes the law and is generally a valid exercise of Congress' legislative power, so long as it does not attempt to direct a result by altering legal standards Congress is powerless to prescribe.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

Nina Alvarez files a federal suit in Arizona challenging a Department of the Interior decision about a tract near Tucson. While the case is pending, Congress enacts a statute providing: "Notwithstanding any other provision of law, any action, including any pending action, relating to the Desert Mesa Parcel shall not be filed or maintained in a federal court and shall be promptly dismissed."

If Nina argues the statute violates Article III because it effectively guarantees dismissal of her pending case, which is the strongest response?

Explanation. Under the majority opinion, Congress violates Article III when it compels findings or results under old law, but not when it changes the law. A statute that bars actions relating to identified property from being filed or maintained in federal court and requires dismissal is best read as jurisdiction stripping. Applying that new jurisdictional rule to a nonfinal pending case does not itself violate Article III.