United States v. Kagama, 118 U.S. 375 (1886), is a United States Supreme Court case that upheld the Constitutionality of the Major Crimes Act of 1885. Kagama, a Yurok Native American (Indian) accused of murder, was selected as a test case by the Department of Justice to test the constitutionality of the Major Crimes Act of 1885, which was passed as a rider to an appropriations bill. This Congressional Act gave the federal courts jurisdiction in certain cases of Indian on Indian crimes, even if the crimes were committed on an Indian Reservation. The importance of the ruling in this case was that it upheld the constitutionality of the Major Crimes Act of 1885 and confirmed Congress’ plenary power over Indian affairs. Plenary power over Indian tribes, supposedly granted to the U.S. Congress by the Commerce Clause of the Constitution was not necessary to support by the Supreme Court in this decision; instead, the Court found the power in the tribes status as dependent domestic nations. This allowed Congress to pass the Dawes Act the following year.
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