United States V. Dion - Case History

Case History

The District Court convicted Dion for the shooting of bald eagles in violation of the Endangered Species Act, and for the distribution of carcasses in violation of the Eagle Protection Act. The Court of Appeals for the Eighth Circuit, however, held that members of the Yankton Sioux Tribe have a treaty right to hunt bald eagles within the Yankton Reservation for noncommercial purposes. It also held that the Eagle Protection Act and Endangered Species Act did not abrogate this treaty right. Since neither the District Court nor the jury ruled on whether the killings were for commercial or noncommercial purposes, the appellate court directed that Dion's convictions for shooting bald eagles be vacated. The Supreme Court granted certiorari to determine the correctness of the Eighth Circuit's holding that noncommercial hunting of bald eagles on the Yankton reservation was not punishable under the Endangered Species Act or Eagle Protection Act.