San Carlos Apache Tribe v. Becerra

“[B]ecause the canons of construction applicable in Indian law are rooted in the unique trust relationship between the United States and the Indians, . . . statutes are to be construed liberally in favor of the Indians, with ambiguous provisions interpreted to their benefit.” Montana v. Blackfeet Tribe of Indians, 471 U.S. 759 (1985).

Appellants appealed a motion to dismiss regarding a suit for “contract support costs” (“CSC”) for third-party costs associated with healthcare costs under the Indian Health Services healthcare program for Native American tribes in 2011-2013. On appeal, Appellants argued that the Indian Self-determination and Education Assistance Act (“ISDA”) requires that Indian Health Services must cover the additional CSC as enacted by Congress. 25 U.S.C. §5325(a)(1). Appellees argued that the language of the contract between the tribe and the United States mandates that the CSC be paid by the tribe. “Because the canons of construction applicable in Indian law are rooted in the unique trust relationship between the United States and the Indians, . . . statutes are to be construed liberally in favor of the Indians, with ambiguous provisions interpreted to their benefit.” Montana v. Blackfeet Tribe of Indians, 471 U.S. 759 (1985). Because the contract did not specifically address the third-party costs affiliated with IHS after Congress enacted 25 U.S.C §5325(a), the Court held that the contract was not dispositive for resolving this issue. Reversed and remanded.