Lone Wolf V. Hitchcock - Holding

Holding

The Court held that Congress had the authority to void treaty obligations with Native American tribes because it had an inherent "plenary power":

Authority over the tribal relations of the Indians has been exercised by Congress from the beginning, and the power has always been deemed a political one, not subject to be controlled by the judicial department of the government. —Lone Wolf at 565.

The decision was based, among other things, on a paternalistic view of the United States' relationship with the tribes:

These Indian tribes are the wards of the nation. They are communities dependent on the United States. Dependent largely for their daily food. Dependent for their political rights. They own no allegiance to the states, and receive from them no protection. Because of the local ill feeling, the people of the states where they are found are often their deadliest enemies. From their very weakness and helplessness, so largely due to the course of dealing of the Federal government with them and the treaties in which it has been promised, there arises the duty of protection, and with it the power. This has always been recognized by the executive and by Congress, and by this court, whenever the question has arisen. —Lone Wolf at 567, quoting United States v. Kagama, 118 U.S. 375 (1885).

Congress unilaterally modified many other treaties between Native American tribes and the United States in subsequent years, in part relying on the decision in Lone Wolf v. Hitchcock. The decision has been upheld and cited by the Supreme Court since then, such as in United States v. Dion of 1986.