Stratman

BACKGROUND

Statutory Framework

I. ANCSA

Congress enacted ANCSA in 1971 in order to “resolve land disputes between the federal government, the state of Alaska, Alaskan Natives, and non-native settlers.” Leisnoi, Inc. v. Stratman, 154 F.3d 1062, 1064 (9th Cir. 1998). In its findings and declaration of policy, Congress recognized “an immediate need for a fair and just settlement” of aboriginal land claims that was to be “accomplished rapidly, with certainty, in con- formity with the real economic and social needs of Natives, [and] without litigation . . . .” 43 U.S.C. § 1601(a), (b). In fur- therance of this basic purpose, “Alaskan Natives received, in exchange for the extinction of all claims of aboriginal title, 14128 STRATMAN v. LEISNOI, INC. approximately forty-four million acres of land and nearly $1 billion in federal funds.” Leisnoi, 154 F.3d at 1064. These resources were distributed amongst thirteen “Regional Corpo- rations,” groups of Natives unified by a “common heritage and sharing common interests[,]” 43 U.S.C. § 1606(a), and an unspecified number of “Village Corporations,” corporate enti- ties based around native villages. 43 U.S.C. § 1607. The native…