United States v. Santa Fe Pacific R.R. Co.
United States Supreme Court
314 U.S. 339 (1941)
The Hualapai tribe refused an 1865 offer to relocate to the Colorado River reservation and remained on ancestral land that the government later granted, overlapping, to the railroad's predecessor; after being forcibly removed in 1874, the tribe returned the following year and was allowed to stay during good behavior before finally accepting a separate reservation in 1883. The United States later sued on the Hualapai's behalf to stop the railroad (defendant) from interfering with the tribe's occupancy of land both inside and outside that reservation, and the lower courts ruled for the railroad, finding the government had never recognized Hualapai aboriginal title and that legislative acts had extinguished it.
Whether a tribe's exclusive historical occupancy of a definable ancestral territory establishes aboriginal title without formal government recognition, and whether a statutory requirement of voluntary cession preserved that title until the tribe actually agreed to relocate.