Santa Clara Pueblo v. Martinez

436 U.S. 49 (1978)

Relevant Facts: Martinez and her daughter brought action against the Santa Clara Pueblo in response to a Pueblo membership ordinance that was argued to be discriminatory toward the children of female members, when the father was not a member. The policy in question granted tribal membership to children of fathers who were Pueblo members, but not to those children of mothers who were Pueblo members, but who had been fathered by non-members. It was argued that the governor of the Pueblo and the Pueblo had violated Title 1 of ICRA, the Indian Civil Rights Act (25 USC §§ 1301-1303 (1968)), which guaranteed equal protection of the law. Martinez sought relief in the federal courts. The District Court acknowledged jurisdiction and found for Martinez. The Court of Appeals, while agreeing on jurisdiction reversed on the merits of the case. The Supreme Court granted certiorari.

Legal Issue(s): 1) Does the federal court system have jurisdiction over civil suits of this sort stemming from alleged violations of ICRA? If so, 2) Does the tribe have the authority to distinguish between the children of member fathers and those of tribal mothers with regard to membership qualification.

Holding: 1) No.

Rationale: The Supreme Court essentially vacated the ruling of the appellate court that regarding the authority of the tribe to administer membership standards in the manner contested in that the Court found that the federal system had no jurisdiction over such matters. The Court ruled that there is nothing in the actions of Congress that have specified any remedy for violations of ICRA other than habeas corpus in criminal matters. Therefore, to hear petition for declarative or punitive damages in a civil matter of this sort would be violation of the immunity enjoyed by the Indian tribe. That immunity remains in force unless waived by the tribe or explicitly removed by action of Congress, neither of which occurred.

Disposition: Reversed on the question of jurisdiction by 7-1 vote. Marshall wrote for majority with White dissenting and Blackmun abstaining.