Salazar v. Ramah Navajo Chapter, 567 U.S. 182 (2012), was a United States Supreme Court case in which the Court held that the United States government, when it enters into a contract with a Native American Indian tribe for services, must pay contracts in full, even if Congress has not appropriated enough money to pay all tribal contractors.
[4] "[T]he Ramah Navajos played a leadership role in defending indigenous self-determination efforts in the United States",[5] beginning with the establishment of a reservation school over the protests of local non-Indians.
[19] The BIA denied the appeal, noting even so that the Chapter was correct that including the state grants in the calculation was contrary to law.
The circuit court held that the 1988 amendment to IDEAA was intended to correct the chronic underfunding of BIA and IHS contracts with tribes, especially in regards to indirect costs.
[25] On remand, both the United States and the Chapter entered into settlement talks, eventually settling a portion of the claims.
[26] On December 6, 2002, the district court entered a final judgement on most of the remaining issues, finding for the Chapter and the other tribes in the class for $29,000,000 on the claims, $5,800,000 in attorney's fees, and $243,496 in costs.
[32] The BIA appealed to the Supreme Court of the United States, which granted certiorari to hear the case in order to settle a circuit split.
[37] Freeman argued that the government's liability does not extend past the amount of money that Congress has appropriated for all of the contracts.
[39] The Ramah Navajo Chapter was represented by Carter G. Phillips, who argued that this was a simple contract case to which the Ferris doctrine[fn 12] applied.
[43] Phillips noted that the statute was clear, and if it was not, the canons of statutory construction required that the ambiguity be resolved in the tribes favor.
[44] Amicus curiae briefs were filed in support of the Chapter by the National Congress of American Indians (joined by the Coalition of Indian Tribes and Tribal Organizations), the Arctic Slope Native Association, and the Chamber of Commerce of the United States of America (joined by the National Defense Industrial Association).
Roberts asserted that the Court's decision would cause the BIA to exceed the monetary limits for the IDEAA contracts, which were set by Congress under its appropriation authority.
In addition, Roberts noted that Congress expressly forbade the BIA from reducing payments to other tribes and programs to pay an IDEAA contract.
The Principal Chief of the Cherokee Nation, Bill John Baker, met with U.S. President Barack Obama on July 20, 2012 to discuss the issue.