United States v. Kagama

In 1885, Kagama and Mahawama (defendants), both members of the Klamath tribe, were indicted for killing another tribe member on tribal land in California. Although the crime was Indian-on-Indian, they were charged federally under the Major Crimes Act of 1885, which gave federal courts jurisdiction over major crimes, including murder, between Indians. The district court split over whether Congress had constitutional power to pass the Act, and certified the question to the Supreme Court.