United States v. Idaho

At issue in this case is the ownership of submerged lands lying within the present-day boundaries of the Coeur d’Alene Indian Reservation, which was originally set aside by executive order in 1873. After a nine-day trial involving multiple expert and lay witnesses, extensive written reports, scientific studies, and historical documents, the district court issued a lengthy and meticulous decision in which it concluded that the United States retained these submerged lands for the benefit of the Coeur d’Alene Indian Tribe (the “Tribe”). The court thus entered an order quieting title to the beds and banks of the Coeur d’Alene Lake (the “Lake”) and the St. Joe River 2 (collectively, the “submerged lands”) in favor of the United States, as trustee, and the Tribe, as the beneficially interested party of the trusteeship. The State of Idaho (the “State”) appeals that order along with related orders giving the Tribe exclusive right to these submerged lands. We affirm the judgment of the district court. Congress’s course of conduct in the late 1880s-in the years immediately preceding Idaho’s statehood in 1890-demonstrates that it intended to defeat the State’s title to submerged lands within…