[1][9][10] In 1971, 1,465 individuals who owned allotments filed a lawsuit in the Court of Claims alleging that the United States had mismanaged the timber resources on the reservation.

[10] The Court of Claims denied the motion, basing their jurisdiction to hear the case under the Indian General Allotment Act.

The Shoshone tribe of the Wind River Indian Reservation filed an amicus curiae brief in support of the tribal members.

He concluded that the plain language of the statutes created a trust relationship between the United States government and the plaintiffs.

Powell stated that without explicit language establishing liability on the government, there can be no valid claim or subject matter jurisdiction.

[1][5][11] Mitchell was the first case where the Supreme Court ruled that the United States government could be liable for monetary damages for a trust relationship.

[21] Since the fiduciary duty has been established, tribes have been using it to ensure that the Secretary of the Interior takes their needs into consideration, especially in the area of mineral and timber resources.