Quechan Tribe of the Fort Yuma Indian Reservation v. United States

MEMORANDUM

Plaintiff Quechan Tribe alleges that the United States violated statutory, common law, and constitutional duties that it owes the Tribe when it provided inadequate medical care at the Fort Yuma Service Unit of the Indian Health Service (“IHS”). According to the complaint, the Unit’s facilities are the oldest in the IHS system, are in a condition of disrepair, and create unsafe conditions for tribal members seeking care. The district court granted the government’s motion to dismiss. We have jurisdiction under 28 U.S.C. § 1291 and we affirm.

Plaintiff alleges that the United States has a duty to meet a specific standard of adequate medical care based on (1) the federal-tribal trust relationship, and (2) two federal statutes, the Snyder Act and the Indian Health Care Improvement Act. However, the federal-tribal trust relationship does not, in itself, create a judicially enforceable duty. Rather, “trust obligations of the United States to the Indian tribes are established and governed by statute rather than the common law, and in fulfilling its statutory duties, the Government acts not as a private trustee but pursuant to its sovereign interest in the execution of federal…