Lone Wolf v. Hitchcock | |
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Argued October 23, 1902 Decided January 5, 1903 |
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Full case name |
Lone Wolf, Principal Chief of the Kiowas, et al., Appellants., v. Ethan A. Hitchcock, Secretary of the Interior, et al., Appellees. |
Citations | 187 U.S. 553 (more)
187 U.S. 553, 23 S.Ct. 216, 47 L.Ed. 299
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Prior history | 19 App. D. C. 315 |
Holding | |
Congress has plenary power to unilaterally abrogate treaty obligations between the United States and Native American tribes. | |
Court membership | |
Case opinions | |
Majority | White, joined by Brewer, Brown, Fuller, Holmes, Peckham, McKenna, Shiras |
Concurrence | Harlan |
Laws applied | |
U.S. Constitution, Article V |
Lone Wolf, Principal Chief of the Kiowas, et al., Appellants., v.
Lone Wolf v. Hitchcock, 187 U.S. 553 (1903) was a United States Supreme Court case brought against the US government by the Kiowa chief Lone Wolf, who charged that Native American tribes under the Medicine Lodge Treaty had been defrauded of land by Congressional actions in violation of the treaty.
The Court declared that the "plenary power" of the United States Congress gave it authority to unilaterally abrogate treaty obligations between the United States and Native American tribes. The decision marked a departure from the holdings of Cherokee Nation v. Georgia, 30 U.S. 1 (1831), and Worcester v. Georgia, 31 U.S. 515 (1832), which had shown greater respect for the autonomy of Native American tribes.
The Kiowa tribe is a Native American tribe that has historically inhabited the southern Great Plains what is now present-day Oklahoma, Texas, Kansas, and New Mexico. Originally from the northern great plains along the Platte River, and under pressure from other tribes, they eventually moved and settled south of the Arkansas River primarily in present-day Oklahoma. The Kiowa had a long history of close association and alliance with the Kiowa-Apache or Plains Apache. Around 1790, the Kiowa also formed an alliance with the Comanche and formed a barrier to European-American incursions into their territories. This alliance made travel on the Santa Fe Trail hazardous, with attacks on wagon trains beginning in 1828 and continuing thereafter.