Patchak v. Zinke

“Whether a statute directing the federal courts to ‘promptly dismiss’ a pending lawsuit following substantive determinations by the courts (including this court's determination that the ‘suit may proceed’) – without amending the underlying substantive or procedural laws – violates the Constitution's separation of powers principles.”

Petitioner is a resident near a tract of land that was seized by the Department of the Interior and put into trust to be used by the Gun Lake Tribe to erect a casino. Petitioner appeals a decision by the lower court to dismiss his claim based on the fact that, after the Secretary of the Interior’s decision, Congress subsequently passed the Gun Lake Act, which removed jurisdiction from the federal courts for any actions pertaining to that land. The district court determined that because the Act was a constitutionally valid exercise of Congressional power, the action was properly dismissed. Petitioner then appealed to the District of Columbia Circuit, which affirmed the judgment below finding that the Act was constitutionally valid and so dismissal was proper. Petitioner then appealed to the United States Supreme Court, which granted certiorari. In their petition, Petitioner argued that: 1) Congress has impermissibly taken jurisdiction away from the federal courts without amending the underlying laws, 2) Regardless of what Congress intended to accomplish, its actions did not adequately place the land in trust, and 3) Congress’s action offends the principles of the separation of powers doctrine.