United States v. Mitchell

Under the General Allotment Act, the government allotted land to Mitchell and other individual Indians (plaintiffs) in 1887, much of which was uninhabitable but contained valuable timber; a 1910 Act authorized the Secretary of the Interior to sell that timber on the Indians' behalf and pass along the proceeds, with accompanying regulations governing the process. When the Indians discovered the Secretary was mismanaging this process against their best interests, they sued for breach of trust; after the Court of Claims initially found a fiduciary duty, the Supreme Court reversed and remanded, holding the Act alone did not create a fiduciary relationship, but on remand the Court of Claims again found the United States liable for breach of trust, and the Supreme Court granted certiorari a second time.