Yellen v. Confederated Tribes of Chehalis Reservation

This U.S. Supreme Court case arose from a dispute over the distribution of $8 billion in COVID-19 relief funds allocated for "Indian tribes" under the Coronavirus Aid, Relief, and Economic Security (CARES) Act. The Confederated Tribes of the Chehalis Reservation, along with other federally recognized tribes, sued Treasury Secretary Janet Yellen, arguing that Alaska Native Corporations (ANCs)—for-profit entities created under the Alaska Native Claims Settlement Act—do not qualify as "Indian tribes" and should not share in the funds. The tribes contended that including ANCs would reduce the monetary allocation for sovereign tribal governments. The federal government maintained that ANCs fell within the broad statutory definition of the ISDEAA, which the CARES Act explicitly incorporated. The case carried profound financial consequences for tribal governments nationwide during the pandemic.

In a 6-3 decision delivered by Justice Sonia Sotomayor, the U.S. Supreme Court ruled that Alaska Native Corporations are indeed "Indian tribes" within the meaning of the ISDEAA and thus are eligible to receive CARES Act relief funds. The Court employed a textualist approach, holding that ANCs satisfy the ISDEAA's definition because they are "recognized as eligible for the special programs and services provided by the United States to Indians because of their status as Indians."

Whether Alaska Native Corporations, which are for-profit entities established under the Alaska Native Claims Settlement Act, qualify as "Indian tribes" under the Indian Self-Determination and Education Assistance Act (ISDEAA) and are therefore eligible to receive a share of the $8 billion in emergency COVID-19 relief funds set aside for tribal governments by the CARES Act.

The ruling had an immediate and significant financial impact, securing hundreds of millions of dollars in pandemic relief for Alaska Native communities through ANCs, but simultaneously reducing the per-capita share for many federally recognized tribes in the lower 48 states, exacerbating tensions regarding tribal recognition and resource allocation. The decision reinforced a broad, statutory definition of "Indian tribe" that extends beyond traditional sovereign governmental bodies to include specific Congressionally-created corporate entities, setting a major precedent for federal Indian law and future relief legislation.