Background
The Indian Mineral Leasing Act (IMLA) of 1938 was brought to the attention of the Navajo people in 1964 when the Navajo Nation entered into an agreement with a third party to lease a substantial portion of Navajo land for coal mining. The Navajo Nation complained that the United States acted in the interests of a coal mining company, and not in the interests of the Navajo Nation, when negotiating the rate of royalty payments owed on coal mined from Navajo land. The Court of Federal Claims dismissed the complaint, ruling that although the United States had breached its fiduciary obligations to the Navajo Nation, this breach was not actionable because the United States did not have a trust relationship with the Navajo Nation and monetary relief was not available. The court of appeals reversed, holding (1) that a trust relationship existed and exists with the Navajo Nation, and (2) monetary damages are an available remedy for breach of this trust.
Read more about this topic: United States V. Navajo Nation
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