LEAVE NO TRIBE BEHIND: NARF Takes on a Class Action for ...

The Native American Rights Fund’s (NARF’s)Legal Review readers no doubt are acutely awareof Cobell, et al. v. Kempthorne, et al., the lawsuitthat NARF helped file more than ten years agoon behalf of hundreds of thousands of individualIndians for the mismanagement of their trustfunds by the United States government. Ourreaders also know that the Cobell litigation con-tinues to this day, with the federal governmentsteadfastly refusing accountability for its grossmismanagement of individual Indian trustfunds. What readers may not know is that Cobellwas only the tip of the iceberg. The mismanage-ment by the federal government of tribal trustfund accounts far exceeds that of individualIndian trust fund accounts; so much so that U.S.Attorney General Alberto Gonzales, in his 2005testimony to a U.S. House of RepresentativesCommittee, estimated that the United States’potential liability for tribal trust fund misman-agement may exceed $200 billion. To addressthis liability Congress established a deadline ofDecember 31, 2006 after which tribes likely wereto be precluded from challenging the misman-agement of their tribal trust funds. Therefore,

on December 28, 2006, at the direction of elevennamed plaintiff tribes (recently amended totwelve tribes), NARF filed a class action lawsuitin federal district court in Washington, D.C. onbehalf of potentially over two hundred and twenty-five (225) tribes, seeking full and completeaccountings from the federal government forhundreds of tribal trust fund accounts worth billions of dollars. This lawsuit is named NezPerce Tribe, et al. v. Kempthorne, et al.

History of the Government’s Trusteeship ofTribal Trust Funds

The federal government long ago assumed the role of trustee for tribal trust funds and

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Leave No Tribe Behind ........................................page 1NARF Director testifies before Senate Committee ..page 7CASE UPDATES- Nez Perce Water Settlement to be Implemented ..................................................................................page 13- NARF Assists the Pawnee Nation .................. page 13

- NARF Launches National Media Campaign ..page 14- John Echohawk & NARF Honored ................page 15NEW Board Members ........................................page 16CALLING TRIBES TO ACTION! ........................page 17Indian Law Library .......................................... page 18NARF ................................................................ page 19

LEAVE NO TRIBE BEHIND: NARF Takes on a ClassAction for Billions of Dollars of GovernmentMismanagement of Tribal Trust Funds

created the accounts at issue. The trusteeship isdeeply rooted in treaties, laws and agreements.Tribal trust funds come from revenues generated by the development of tribal naturalresources managed by the federal governmentsuch as timber, minerals, and oil and gas; courtjudgments entered against the United States forthe unlawful appropriation of Indian land andproperty; and income from the investments bythe federal government of money held in theaccounts. Tribal trust funds are solely monies oftribes; they are not taxpayer dollars and they arenot federal program funding. In fact, the federalgovernment gave tribes no choice about the creation of these trust fund accounts, some ofwhich date back to the early 1800s. “Imagine ifthe law in the United States required you to haveno choice of where to bank your money,” statesMelody McCoy, the lead NARF attorney in NezPerce Tribe v. Kempthorne. “You can’t choosebetween Chase Bank, or Wells Fargo, or yourlocal or state bank. You have to bank with thefederal government. That’s what federal lawrequired of tribes historically. And tribes ofcourse followed the law.” As a result, the federalgovernment today purports to hold about $3 billion in approximately 1,450 trust fundaccounts for over 250 tribes.

NARF Executive Director John Echohawkexplains the problems created for tribes. “Whatif your bank never told you how much moneywas in your account, or how or whether yourmoney was being invested?” Echohawk contin-ues, “By the early 1980s, tribes increasinglywere concerned that they never had gotten andcould not get accountings of their trust funds.The Government Accounting Office (GAO) andthe U.S. Department of the Interior’s Office ofthe Inspector General (OIG) issued key reportsthat identified major problems in the govern-ment’s management of Indian trust funds. The reports detailed records lost or never kept,systems that didn’t work or weren’t coordinated,and policies that were deficient or never evenexisted. As a result of these concerns and findingsin 1987 Congress began ordering expressly theDepartment of the Interior, which is the agency

with primary responsibility for Indian trustfunds, to audit and reconcile the accounts –which never had been done – and to provide fulland complete accountings of the funds to tribesand individual Indians whose money was in theaccounts.”

The 1994 Trust Reform ActCongress’ attention to the problems culminated

in the enactment of the American Indian TrustFund Management Reform Act of 1994. As theInterior Department OIG explained and recognized in a December 2006 Auditor’s Report;

“[t]he Act recognizes the unique trust rela-tionship that exists between the Indian tribes,individual Indians and the United StatesGovernment. Agreements between the U.S.Government and the various Indian tribes,many of these in the form of treaties recognizethe sovereignty of tribes. During the course ofthe Nation’s history and the U.S. Government’sevolving policies toward Indian tribes, the trustrelationship has retained characteristics basedupon tribal sovereignty. The United StatesCongress has designated the Secretary [of theInterior] as the trustee delegate with responsi-bility for the financial and non-financialresources held in trust on behalf of American

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Presentation by NARF tribal trust fund case attorneysDon Wharton and David Gover to tribal trust fund clients.

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Indian tribes, individual Indians, and other trustfunds. In carrying out the management andoversight of the Indian trust assets, theSecretary has a fiduciary responsibility to ensuremonies are received from the use of Indian landsand the extraction of natural resources fromIndian lands, distribute such monies collectedto the appropriate beneficiaries, ensure thattrust accounts are properly maintained andinvested, and ensure that accurate and completereports are provided to the trust beneficiaries inaccordance with applicable law.”

The 1994 Act requires specifically the InteriorDepartment to provide full and complete trustfund accountings to Indian account holders andCongress. The Act even created within theInterior Department a new Office of the SpecialTrustee (OST) for American Indians (OST) tooversee implementation of Indian trust fundmanagement reforms. John Echohawk remem-bers that many tribal leaders were encouragedby the 1994 Act, and its promises, but that theyalso were cautious because of the history andthe depth of the government’s misaccountingand mismanagement.

The Arthur Andersen ProjectThe reality of the situation was about to set in.

By the early 1990s, the Bureau of Indian Affairs(BIA) within the Interior Department admittedthat it was incapable of complying with themandates for full and complete historicalaccountings, audits, and reconciliations ofIndian trust funds. The BIA hired the accountingfirm of Arthur Andersen, LLP to tackle the project under a $12 million contract. Early on,Arthur Andersen concluded that due to the levelof effort and associated expenses and the poten-tial for missing documentation, it would costover $280 million to reconcile the trust fundaccounts of individual Indians. When the federalgovernment did nothing more regarding theindividual Indians’ trust fund accounts, theCobell litigation was filed in 1996.

Arthur Andersen’s Indian trust fund work ultimately consisted of researching only tribaltrust fund accounts for the limited time period

of July 1972 through September 1992. And, bythe project’s end Arthur Andersen’s contract hadbeen modified twenty-nine times – primarily toreduce the project’s scope and procedures and increase its cost to $21 million. ArthurAndersen openly determined that insufficientrecords were available for even the limited timeperiod for which it was examining tribal trustfund accounts to conduct full accountings orreconciliations of the accounts. Instead, the BIAagreed to “alternative procedures” that ArthurAndersen applied to tribal trust funds. Duringthe Arthur Andersen project years, Congressmandated that any Indian trust fund audit andreconciliation work be certified by an indepen-dent third party. In September 1993 the BIAhired Coopers & Lybrand, CPA for the certifica-tion work. But the BIA terminated Coopers &Lybrand’s contract in November 1995 beforecertification could be completed.

Arthur Andersen concluded its tribal trustfund project work in 1995. In 1996 the BIA provided all tribal account holders with “Agreed-Upon Procedures Engagement Reports” of theirtrust fund accounts prepared by ArthurAndersen for fiscal years 1973 – 1992. Melody

McCoy remarks that, “Since the ArthurAndersen project, everyone – including ArthurAndersen itself, the BIA, the OST, and the GAO –has admitted that the Arthur Andersen reportsare not full and complete accountings. Everycouple of years – 2003, 2005, and 2007 – the OIGand the GAO tell Congress that tribal trust fundaccount balances are inaccurate and that thegovernment likely is liable for this. But the gov-ernment continues to try and persuade tribes,Congress, and the courts that there are “noknown errors” in tribal trust fund accounts andthat the Arthur Andersen reports are full andcomplete accountings. On this point Congressfinally said “enough’s enough” and required thematter to go to court by December 31, 2006.”John Echohawk adds, “The bottom line is thatdespite the agency reports, twenty years of congressional mandates, and $21 million spenton the Arthur Andersen contract, to date notribe has gotten a full and complete accountingof its trust funds. How in the world can tribeseven begin to know the extent of the harmthey’ve suffered when they don’t have the mostbasic information about their accounts?”

Nez Perce Tribe v. Kempthorne is One of Over100 Tribal Trust Cases

Given the congressional deadline of December31, 2006, NARF did not hesitate to file Nez PerceTribe v. Kempthorne. Originally brought byeleven named plaintiff tribes: the Nez PerceTribe (Idaho); the Mesaclero Apache Tribe (NewMexico); the Tule River Indian Tribe (California);the Hualapai Tribe (Arizona); the Yakama Nation(Washington); the Klamath Tribes (Oregon); the Yurok Tribe (California); the Cheyenne-Arapaho Tribe (Oklahoma); the Pawnee Nation(Oklahoma); the Sac and Fox Nation(Oklahoma); and, the Santee Sioux Tribe(Nebraska), on April 2, 2007 these eleven tribeswere joined by a twelfth tribe, the Tlingit andHaida Indian Tribes (Alaska). The lawsuit seeksto be a class action on behalf of all tribes thathave not received full and complete accountingsof their trust funds, that have not filed their own


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Tribal trust fund case clients meeting at NARF with attorneys and staff.



separate action for accountings, and that wish toremain in the class if a class is certified by thecourt.

In fact by December 31, 2006 about seventy(70) tribes had filed their own separate lawsuitsagainst the federal government alleging tribaltrust fund misaccounting and mismanagement,bringing the total number of such cases to overone hundred. But, as John Echohawk notes,“That means about two hundred and twenty-five(225) tribes either did not have the financialresources or the needed information to file theirlawsuits by the deadline. NARF wants ‘No TribeLeft Behind’ in what is possibly the biggest fiscalcrisis this country ever has known.” MelodyMcCoy agrees that, “Not since the days of theIndian Claims Commission have so many tribesfiled lawsuits against the United States over thesame issue – in this instance, fiduciary misac-counting and mismanagement.”

The Administration’s $7 billion settlement offerBut the government does not want these

issues going to court. On March 1, 2007, theBush Administration wrote the U.S. SenateCommittee on Indian Affairs that it would settlethe Cobell case and all tribal trust claims, as wellas implement needed Indian trust managementreforms called for by the 1994 Act and by thecourts to date in the Cobell litigation, for anamount of “up to $7 billion over a ten-year period.”Despite many flaws in the Administration’sMarch 1, 2007 proposal, it notably marks thefirst time that the government ever has put adollar figure to its Indian trust fund misac-counting and mismanagement. The SenateCommittee on Indian Affairs quickly called inthe Secretary of the Interior and the U.S.Attorney General to explain their proposal inmore detail.

At the Senate Committee on Indian AffairsOversight Hearing on Indian trust fund litigationon March 29, 2007, the government was unableto explain how its estimate of the government’sliability went from “as much as $200 billion” to“up to $7 billion.” The Cobell plaintiffs, NARF,and others testified that the Administration’s

proposal was essentially “a slap in the face” and“patently in bad faith.” They reminded Congressthat only a few months ago, in October 2006,Congress had suggested that the Administrationspend $8 billion to resolve all Indian trust litiga-tion pending at that time – which then wasabout thirty cases – and to implement the neededIndian trust management reforms. JohnEchohawk specifically testified that, “theAdministration’s March 1, 2007 proposalremarkably makes no reference to the over 70new tribal trust claims filed in court since theOctober 2006 proposal. This 200% increase inthe number of lawsuits and the potentialaccountability and liability of the federal gov-ernment should give the Administration everyreason to begin good faith negotiations directlywith the tribal plaintiffs to develop trust claimsettlement proposals which tribes can support.The Administration’s March 1, 2007 proposalsimply does not reflect a good faith effort. Itblithely ignores the horrendous financial crisisthat has prompted a whole-scale legal war beingwaged by tribes throughout the country to make

the government accountable for its basic fiduciary obligations – obligations which havebeen rectified honorably when breached on thesame level by financial institutions responsiblefor holding and managing the accounts andfunds of non-Indians, states, and local govern-ments on deposit and entrusted with their careand safe-keeping.”

Of course John Echohawk was referring to theover $125 billion authorized by Congress in the1990s to be spent to bail out the savings andloan institutions industry from a financial scandal in which the government had no fidu-ciary trust obligations. And, Echohawk pointedout, Congress currently is considering a $165billion bail out of subprime mortgage borrowerswhose homes are being foreclosed. What, if any-thing, Congress will do to hold the governmentaccountable for its Indian trust fund misac-counting and mismanagement remains to beseen. As John Echohawk observed after theSenate Hearing, “I think that Congress hasheard enough about the Administration’s proposal to “just say no” to including in it all ofthe tribal claims. I believe that we will live tofight this out in Court.”

The Road AheadThus, NARF continues to move forward Nez

Perce Tribe v. Kempthorne. The government’sanswer to the First Amended Complaint is dueMay 11, 2007. The Plaintiffs have thirty daysafter that to move for class certification. As Melody McCoy, who has been litigating tribaltrust fund claims against the government forover ten years knows, “These tribal trust claimsare a real battle. NARF is grateful for the lead-ership of the tribes who are willing to stand upin this fight for Indian justice.”

The twelve named plaintiff tribes, members ofNARF’s Board of Directors, and NARF’s tribaltrust fund litigation team also have hit the roadfrom coast to coast to explain and answer questions about Nez Perce Tribe v. Kempthorne.Since January 2007, they have appeared at various national, regional, and state tribal orga-nizational meetings throughout Indian country

including those of the National Congress ofAmerican Indians, the Inter-Tribal MonitoringAssociation, the Affiliated Tribes of NorthwestIndians, the Eight Northern Pueblos, the United Indian Nations of Oklahoma, and theFederal Bar Association’s Annual Indian LawConference. John Echohawk reports that theresponse from tribes to the lawsuit has beenoverwhelmingly favorable. “NARF’s undertakingof this is appreciated. Tribes are anxious to seeif the court will certify a class and how the courtwill hold the government accountable for thismess. And it is a big mess.”

For additional information regarding NezPerce Tribe v. Kempthorne please visit www.tribaltrust.com. ❂


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(Testimony of NARF Executive Director beforethe United States Senate Committee on IndianAffairs on March 29, 2007)

Good morning Mr. Chairman and members ofthe Committee. Thank you for the opportunityto offer testimony at this oversight hearing onIndian trust litigation. I am pleased to assist theCommittee in understanding this litigation andin exploring the role of Congress in resolvingthe litigation.

The Native American Rights Fund (NARF)serves as legal counsel to the plaintiffs in theCobell litigation, which involves the trust claimsof individual Indians. NARF also serves as legalcounsel to Indian tribes in three separate cases:1) Chippewa Cree Tribe of the Rocky Boy’sReservation, Little Shell Band of ChippewaIndians, Turtle Mountain Band of ChippewaIndians, and White Earth Band of MinnesotaChippewa Indians v. United States, No. 92-675Lin the U.S. Court of Federal Claims (filed Sept.30, 1992); 2) Chippewa Cree Tribe v.Kempthorne, No. 02-00276- JR in the U.S.District Court for the District of Columbia (filedFeb. 11, 2002); and, 3) Nez Perce Tribe, et al. v.Kempthorne, et al., No. 06-02239 in the U.S.District Court for the District of Columbia (filedDec. 28, 2006). Nez Perce Tribe, et al. v.

Kempthorne, et al., was filed by eleven namedtribal plaintiffs as a class action on behalf ofabout 220 tribes that have not filed their owntrust accounting lawsuits. I am here today onlyon behalf of NARF’s trust claim client tribes; not the Cobell plaintiffs.

My testimony today makes three points: 1) there are now over 100 trust claim lawsuitsagainst the United States in federal courts onbehalf of over 285 federally-recognized tribes.The Committee needs to understand these tribaltrust claims and the potential accountability andliability of the United States; 2) at least withrespect to a legislative settlement of the trustclaims of Indian tribes, the Administration’s let-ter proposal to this Committee of March 1, 2007is unacceptable; and, 3) at least some tribes arewilling to explore legislative efforts to settletheir trust claims that respect the rights, claims,and options of each tribe. I now will discussthese three points in more detail.

1. There now are pending against the government 108 tribal trust claim lawsuits

“Tribal trust accounts” and “tribal trust funds”generally include: 1) monetary paymentsrequired by treaty or in satisfaction of judg-ments against the United States, such as Indian

NARF Director testifies before Senate Committee


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Claims Commission awards; and, 2) income orproceeds earned by tribes from land and naturalresources that the government holds in trustand manages for tribes. Tribal trust accountsand trust funds also include income earned oninterest earnings and investments by the gov-ernment of the funds themselves. The point hereis that tribal trust accounts and trust funds arenot taxpayer dollars and they are not appropriatedfederal program funds. They are the tribes’ ownmoney secured through treaties, court cases,statutes, and other federal law. The govern-ment’s misaccounting and mismanagement oftribal trust accounts and funds strikes at thevery core of the federal trust responsibility toIndian tribes.

The United States unilaterally assumed fidu-ciary trusteeship of tribal trust accounts andfunds in 1820. Since then Congress has dele-gated responsibility for the fiduciary trusteeshipof tribal trust accounts and funds primarily to the Departments of the Interior and theTreasury. Last month the GovernmentAccountability Office testified before the HouseNatural Resources Committee that the UnitedStates presently holds about $2.9 billion inabout 1,450 trust accounts for over 250 tribes.See U.S. Government Accountability Office,Testimony before the Committee on NaturalResources, House of Representatives, Departmentof the Interior Major Management Challenges10, GAO-07-502T (Feb. 2007).

With respect to tribal trust accounts andfunds, the United States is like a bank with atrust department. In fact historically under federal law tribes have had no choice but to bankwith the United States. Tribes’ economic well-being hinges upon proper fiduciary care of theirmonies by the government, just as privateinvestors, states, and local governments dependon banks, savings and loan companies, andinvestment houses to ensure that their assetsare properly accounted for and managed.Imagine the widespread outcry if banks, savingsand loan companies, and investment housesthat were chosen by investors were to fail tomeet their fiduciary obligations. Undoubtedly

such harm would be corrected.There are pending in federal courts against the

government 108 tribal trust accounting andtrust mismanagement lawsuits. Sixty-one (61)of these cases are in the U.S. Court of FederalClaims seeking money damages. Thirty-seven(37) cases are in the U.S. District Court for theDistrict of Columbia seeking accountings andother forms of equitable relief. Another ten (10)cases seeking accountings and other forms ofequitable relief are in other federal districtcourts. NARF has been tracking these cases.Attachment A to my testimony today showsthese 108 cases. The U.S. Department of Justicealso has been tracking these cases and has filedin court similar lists of “Current Tribal TrustAccounting and Trust Mismanagement Cases” asExhibits to its Motions in the cases. AttachmentB to my testimony today is one of the JusticeDepartment’s lists. The Justice Department’scount is five lower than ours apparently due tosome case consolidations and categorization differences.



Many tribes have been affected by the allegedfederal misaccounting for and mismanagementof their trust accounts and funds. Trust claimcases have been filed on behalf of over 285 federally-recognized tribes. Sixty-nine (69) tribeshave filed their own cases. Of the 69 tribes thatfiled their own cases, twelve (12) filed cases onlyin federal district courts. Twenty-two (22) tribesfiled cases only in the Court of Federal Claims.Thirty-five (35) tribes filed cases in both federaldistrict court and the Court of Federal Claims.NARF filed a case in the U.S. District Court forthe District of Columbia for full and completetrust fund accountings on behalf of elevennamed plaintiff tribes, Nez Perce Tribe, et al. v.Kempthorne, et al., which seeks class action status on behalf of all other tribes that did notfile their own cases for full and completeaccountings and that do not wish to excludethemselves from the class for their own reasons.

Over seventy (70) of these 108 tribal trustclaim cases are relatively new. They were filedlate last year. As you know, Congress has codi-fied the inherent obligation of the United Statesas the trustee for tribal trust accounts and fundsto provide “full and complete accountings” totribal beneficiaries. See Cobell v. Norton, 240F.3d 1081, 1102 (D.C.Cir. 2001). For the pasttwenty years Congress has told the governmentto provide full and complete trust accountingsto tribes. See, e.g., Pub. L. No. 100-202, 101Stat. 1329 (1987); see also 25 U.S.C. Sec. 4044.NARF is extremely concerned that to date notribe has received a full and complete accountingof its trust accounts and funds.

Back in the 1990s, unable to comply withthese congressional mandates on its own, theBureau of Indian Affairs (BIA) within the U.S.Department of the Interior contracted with theaccounting firm of Arthur Andersen to examinetransactions in tribal trust accounts for the limited time period of July 1972 throughSeptember 1992. In 1996 the BIA provided tribal account holders with Arthur Andersen“Agreed-Upon Procedures Engagement Reports”of their trust accounts for this limited time period.

Even though everyone – including ArthurAndersen itself, the BIA, the Office of the SpecialTrustee, and the Government AccountabilityOffice – has admitted that the Arthur Andersenreports are not full and complete accountings,the government has tried to get tribes to agreethat the Arthur Andersen reports are full andcomplete accountings.

More importantly, the general statute of limitations for claims against the governmentprovides that civil actions against the govern-ment shall be barred unless filed within six yearsafter the right of action first accrues. 28 U.S.C.Sec. 2401. In 2002, six years after the ArthurAndersen reports were sent to tribes, Congressenacted legislation to “Encourage the NegotiatedSettlement of Tribal Claims, Public Law No.107-153.” This legislation provided, amongother things, that, “Notwithstanding any otherprovision of law, for purposes of determining thedate on which an Indian tribe received a recon-ciliation report for purposes of applying a statueof limitations, any such report provided to orreceived by an Indian tribe in response to section 304 of the American Indian Trust FundManagement Report Act of 1994 (25 U.S.C.4044) shall be deemed to have been received by the Indian tribe on December 31, 1999.” In2005, this legislation was amended to providethat the reports shall be deemed to have beenreceived on December 31, 2000. Pub. L. No.109-158.

But, in the last congressional session, therewas no further extension of the date in this legislation. By late last year, many tribes wereconcerned that their right to claim that theArthur Andersen reports are not “full and com-plete accountings” sufficient to commence therunning of any applicable statutory limitationsperiod on their trust claims would be lost foreverafter December 31, 2006. Tribes feared that thiswould jeopardize their right to have thegovernment ever provide full and completeaccountings of their trust accounts and funds.The result of this predicament was a 200%increase in the number of trust claims filed bytribes against the government. As stated earlier,

now there are 108 tribal trust claim lawsuits.This is a financial crisis in Indian country andfor the United States.

This financial crisis is not new. The legislationto Encourage the Negotiated Settlement ofTribal Claims merely informed the timing of themany recently-filed tribal trust claims lawsuits.Tribes have been filing such lawsuits for years.With good reason. Scores of reports – some dating back to the early 1900s – of theGovernment Accountability Office, the InteriorDepartment’s Office of the Inspector General,and the Office of Management and Budget, aswell as reports of this Committee and otherCommittees of Congress have well-documentedthe tremendous problems of the government’smisaccounting for and mismanagement of tribaltrust accounts and funds. What is new is thephenomenal number of lawsuits. Not since theIndian Claims Commission have so many tribesfiled lawsuits against the federal governmentabout the same problem; in this instance fidu-ciary misaccounting and mismanagement.

The pending tribal trust claims in federal district courts seek various forms of equitablerelief. They seek: 1) declarations that the government has fiduciary obligations to tribalbeneficiaries; 2) declarations that the government

is in breach of its fiduciary obligations; 3) fulland complete accountings of tribal trustaccounts and funds; 4) restatement of or restitu-tion to trust account and trust fund balances asif there had been no breaches of trust; and, 5) declarations of future lawful and proper fiduciary accounting for and management oftribal trust accounts and funds.

The tribal trust claims pending in the Court ofFederal Claims seek determinations of liabilityfor misaccounting and mismanagement of tribaltrust accounts and funds and determinations ofmoney damages for the misaccounting and mis-management. Exactly two years ago this month(March 2005), when he testified before theHouse Subcommittee on Justice DepartmentAppropriations, Attorney General Gonzales atthat time estimated that the government’s liability for these tribal trust claims could beover $200 billion. See Statement of Alberto R.Gonzales, Attorney General of the United Statesbefore the U.S. House of Representatives,Committee on Appropriations, Subcommitteeon Science, the Departments of State, Justiceand Commerce, and Related Agencies (Mar. 1, 2005).

Over the years tribes have turned to the courtsfor resolution of their trust claims because the


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government historically and consistently hasfailed to perform its fiduciary trustee duties;ignored the mandates of Congress in laws likethe American Indian Trust Management ReformAct of 1994; and, simply is unable or unwillingto resolve what is perhaps this nation’s biggestfinancial crisis ever. As I will discuss next, thisis still par for the course for this Administration.

2. The Administration’s proposal of March 1,2007 is unacceptable

NARF has reviewed carefully theAdministration’s proposal to settle Indian trustlitigation as set forth in the letter fromSecretary Kempthorne and Attorney GeneralGonzales to this Committee dated March 1,2007. The March 1, 2007 proposal of theAdministration is very sketchy. In manyrespects it is similar to a proposal that theAdministration proposed to Congress fivemonths ago (October 2006) in response to what was then Senate Bill 1439. There is, how-ever, at least one glaring difference. The Administration’s October 2006 proposalwould have provided for resolution of all Indiantrust litigation and other trust reform matterssuch as Indian land fractionation, presumably ata cost set by Congress of $8 billion. The March1, 2007 proposal proposes to resolve all Indiantrust litigation and other trust reform mattersfor an “investment” of $7 billion or less. Inshort, the new proposal offers to do at leastmuch but for at least a full billion dollars lessthan the old proposal. Once again, we see theAdministration taking a step backward.

In comparison to the Administration’s parsi-monious offer of up to $7 billion to address all ofits own past, present, and future Indian trustmisaccounting and mismanagement, in veryrecent times the government expended $125 billion to bail out the savings and loan institu-tions industry from a scandal in which the government had no fiduciary trust obligations.See Timothy Curry and Lynn Shibut, The Cost ofthe Savings and Loan Crisis: Truth andConsequences, FDIC Banking Review (Dec.2000). The government’s honor to vindicate its

own neglect and mishandling of Indian trustaccounts and funds that it chose to managesurely rises at least to the same level as extrica-tion from a disgrace not of its own making.

Of course the Administration’s March 1, 2007proposal also is unacceptable for the same reasonsthat the October 2006 proposal was unaccept-able. These reasons include: 1) the proposal wasdeveloped without consultation with tribal governments; 2) the proposal seeks to resolvearbitrarily trust claims which never have beenadequately analyzed or valued due to the government’s failure to provide full and complete accountings; 3) the proposal would setunprincipled and impractical limits on federalliability for any and all tribal claims of past andpresent federal neglect and mismanagement oftribal trust accounts and resources, and it wouldpreclude any future liability for such claims;and, 4) the proposal would negate thirty-fiveyears of federal law and policy promoting Indianself-determination and adhering to federal-tribalgovernment-to-government relations by forcingon tribes involuntary termination of the federaltrust responsibility.

Another reason that the Administration’s proposal is fundamentally flawed stems from itscomprehensive “packaging.” For several reasons,efforts to settle the Cobell lawsuit, whichinvolves the trust claims of individual Indians,and efforts to settle the trust claims of tribes,should be kept separate. Congress already treatsthe trust accounts and resources of individualIndians and tribes separately in its many Indiantrust statutes. The Cobell lawsuit has its ownhistory – over a decade long now. Before andafter the Cobell lawsuit was filed, tribes havepursued their own trust claims, and they mustbe allowed to continue to do so. Combining res-olution of the Cobell claims and tribal trustclaims into a single legislative settlement isunrealistic and unwise.

Moreover, the Administration’s March 1, 2007proposal remarkably makes no reference to theover 70 new tribal trust claims filed in courtsince the October 2006 proposal. This 200%increase in the number of lawsuits and the

potential accountability and liability of the federalgovernment should give the Administrationevery reason to begin good faith negotiationsdirectly with the tribal plaintiffs to develop trustclaim settlement proposals which tribes cansupport. The Administration’s March 1, 2007proposal simply does not reflect a good faitheffort. It blithely ignores the horrendous finan-cial crisis that has prompted a whole-scale legalwar being waged by tribes throughout the countryto make the government accountable for itsbasic fiduciary obligations – obligations whichhave been rectified honorably when breached onthe same level by financial institutions responsiblefor holding and managing the accounts andfunds of non-Indians, states, and local govern-ments on deposit and entrusted with their careand safe-keeping.

On behalf of its tribal trust claim clients,NARF hopes that, regardless of what theAdministration does on this matter, the SenateCommittee on Indian Affairs will play a respon-sible leadership role in acting on behalf of theUnited States to foster and support government-to-government and good faith settlement oftribal trust claims. I now will talk about howthat can be accomplished.

3. Exploration of Legislative Settlement Effortsthat Tribes can Support

NARF believes that NARF and many tribes andtheir attorneys have a wealth of experience inand expertise regarding tribal trust claims thatcould be valuable to the Committee. NARFstrongly encourages a dialogue between theCommittee and interested tribal trust claimattorneys to explore the viability of legislativemeasures that are constructive in facilitatingresolution of these complex claims.

Just as the Administration attaches a list of“Key Facets of Acceptable Indian Trust Reformand Settlement Legislation” to its March 1, 2007proposal, NARF believes that there may be con-sensus among tribal attorneys regarding at leasta preliminary list of their “Key Facets ofAcceptable Tribal Trust Claims LegislativeSettlement.” At this time this list includes the

following:Tribes are committed to further educatingthe Committee about their trust claims,which are legitimate legal claims notwith-standing attempts to label them as “unrea-sonable;”Any legislative settlement effort mustrespect the claims, rights, and options ofeach tribe, including the prerogative oftribes to pursue their own claims in court, inalternative dispute resolution forums, inadministrative settings, through negotiatedsettlements, or through other forms of claimresolution;As long as legislative settlement provisionsare voluntary for each and every tribe, atleast some tribes and their attorneys arewilling to work together to help theCommittee determine what, if anything, canbe done legislatively to resolve tribal trustclaims. NARF strongly urges the Committee to con-

sider the above tribal Key Facets as a foundationfor approaching and resolving the national tribaltrust accounts and funds crisis. NARF standsready and willing to work with the Committeeand other interested tribal attorneys to developan informal process for exploring a role forCongress in resolving the tribal trust claims crisis.

Thank you for this opportunity to submit testimony. I am available to answer questions atthis time. ❂


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NATIVE AMERICAN RIGHTS FUNDOn May 15, 2004, the Nez Perce Tribe, the State

of Idaho, and the federal Department of theInterior announced publicly that a settlement ofthe tribe’s claims in the Snake River BasinAdjudication (SRBA) had been reached. Since1998, the Nez Perce Tribe, the United States, theState of Idaho, and local communities and waterusers in Idaho had engaged in mediation as part ofthe SRBA to resolve the claims of the Nez PerceTribe in the Snake River and several of its tribu-taries. The SRBA is the legal inventory of about150,000 water rights in 38 of Idaho’s 44 counties.The Nez Perce dispute had been the biggest out-standing dispute in the Snake River Basin.

For the Tribe, the settlement: quantified theTribe’s on-reservation consumptive use reservedwater right at 50,000 acre feet a year with a prioritydate of 1855; established a $50 million multiple-use water and fisheries resources trust fund; pro-vided $23 million for the design and constructionof water supply and sewer system improvementson the reservation; transferred managementauthority of Kooskia National Fish Hatchery to theTribe; and transferred a portion of Bureau of LandManagement-administered land – about 12,000acres – within the Nez Perce Reservation valued at$7 million to the Tribe. The settlement also pro-vided that instream flows will be established andheld by the Idaho Water Resources Board for over200 streams and rivers selected by the Tribe ascritical salmon habitat; required the State of Idahoto administer two cooperative agreements underthe Endangered Species Act; and established aHabitat Fund to provide funding for habitatimprovement projects.

In November of 2004, the United StatesCongress enacted a law – PL 108-447 – approvingthe settlement, and authorizing the payment ofthe settlement funds to the Tribe. President Bushsigned the law on December 8, 2004. In the Springof 2005 both the Idaho Legislature and the Nez Perce Tribal Executive Committee enactedlegislation approving the settlement agreement.

On January 9, 2007, the SRBA Court heard theJoint Motion for Entry of Consent Decree filed bythe Tribe, the United States, and the State ofIdaho, and on January 30, 2007 the presidingjudge entered a written order approving theConsent Decree. No appeals were filed with the Idaho Supreme Court challenging the finalconsent decree.

On April 27, 2007, the State and the Nez PerceTribe certified that all of the Term Sheet conditionshave been met. It is expected that the Secretary ofthe Interior will enter these findings in the FederalRegister. Now that the three sovereigns haveentered their final findings, the settlement provi-sions relating to the transfer of the 11,000 acres ofBLM land; shared management of the DworshakNational Fish Hatchery; and management of the Kooskia National Fish Hatchery will be finallycarried out.

On April 21st, over a 100 tribal members fromthe Pawnee Nation of Oklahoma and their NasharoBand Chiefs gathered at the Pawnee Nation dance-ground to honor writer Roger Welsch and his wife,Linda, for their gift of approximately 60 acres ofland in Nebraska.

Welsch, a writer, stated in an interview with theTulsa World that, “It’s something we had no choicein because it had to be done,” Welsch said. “Thesepeople are not guests on our land, but rather weare guests on their land,” stated Welsch in refer-ence to the fact that Nebraska once served as

CASE UPDATESNez Perce Water Settlement

to be Implemented

NARF Assists the Pawnee Nation inReturn of 60 acres of traditionalhomeland by Nebraska Couple


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part of the traditional homelands of the Pawneeprior to their removal to Oklahoma in the late1800’s.

The deed to the land, located near the LoupRiver and Dannebrog, Nebraska, was given to thePawnee Nation of Oklahoma in a ceremony fol-lowed by a feast, an honor dance, and Mr. Welschand his wife being made honorary members of thePawnee Nation. Speeches were made by a numberof tribal officials, including the President of thePawnee Nation and the Nasharo Chiefs. Otherspeakers included Walter Echo-Hawk, senior staffattorney for the Native American Rights Fund(NARF). NARF currently represents the PawneeNation in the reburial efforts of 800 humanremains in Nebraska. NARF worked with thePawnee Nation and its Repatriation Committee toassist in the facilitation of the transfer of Mr.Welsch’s land to the Pawnee Nation for use as areburial and cultural site. Echo-Hawk also assistedthe tribe in attaining an opinion from theNebraska Attorney General last year that clarifiedthe tribe’s right to conduct reburials on privateland.

In a short speech during the ceremony and hon-oring, Walter Echo-Hawk encouraged PawneeNation leadership to rename the tribe, in light ofthe return of the lands, to “the Pawnee Nation ofOklahoma and Nebraska.”

Mr. Francis Morris, Pawnee Nation RepatriationDirector, explained to a Tulsa World reporter whointerviewed him at the event that, “The Loup River

was a favored site of the Pawnees,” adding “It isour country.” Mr. Morris went on to add that priorto the Welsch’s gift of the land to the PawneeNation, that the tribe had no place to bury theremains of their ancestors. The tribe is currentlycollecting blankets, shawls, and fundraising toassist with the efforts to conduct the reburials thisfall on the land.

On March 26th, 2007, attorneys and staff of theNative American Rights Fund premiered its firstever national, multi-media Public Service AdCampaign at the opening ceremonies of theNational Indian Gaming Association’s annual con-vention and trade show in Phoenix, Arizona. The:60 and :30 second PSA’s, entitled, “The Indian

NARF Launches National MediaCampaign to Mobilize

Intergenerational Support



Wars Never Ended,” is part of a greater campaignto generate renewed awareness and intergenera-tional support for NARF’s continued mission andwork to defend tribal sovereignty and the rightsand lifeways of Indian peoples. The campaign wasalso launched simultaneously online to thousandsof viewers.

NARF has launched its new multi-media ad cam-paign with the goal of reaching out and engagingyounger generations as well as to build unityacross all generations and cultures to join andsupport the struggle to defend tribal sovereignty.“The Indian Wars Never Ended” PSA represents an intergenerational message of NARF as it estab-lishes a modern-day message for modern-daytimes.

Featured in the PSA production are NARFExecutive Director John Echohawk (Pawnee) andmembers of his legal team, as well as the award-winning Pawnee/Seminole hip-hop duo, CultureShock Camp comprised of DJ Shock B and lyricistand PSA composer/producer, Quese IMC, as well asone of Indian Country’s hottest young artists,painter Bunky Echo-Hawk III.

NARF’s “The Indian Wars Never Ended” PSA rep-resents an unprecedented multi-media campaignthat will appear online, and on radio, TV, and inprint publications in the effort to build supportand unify generations and cultures around thedefense of tribal sovereignty and Native rights.The campaign will run throughout the year with anumber of special events, updates, and ways thatcan get involved and mobilize support for NARF inyour own community. To view “The Indian WarsNever Ended” PSA’s and learn more about how youcan take a stand and be a Modern Day Warrior forNative rights visit: www.moderndaywarrior.org.

John Echohawk, NARF Executive Director, washonored with the Tribal Leadership Award by theNational Center for American Indian EnterpriseDevelopment (NCAIED) in Las Vegas in mid-March. Echohawk was honored at the Res2007

Conference which is the largest and longest-running business and trade fair in the UnitedStates. The event is organized annually byNCAIED. More than 2,500 Tribal and Indian business leaders and Fortune 500 Companiesattended the conference this year.

John Echohawk and NARF were honored at theRes2007 Awards Banquet attended by more than750 tribal and business leaders. David Lester(Muscogee Creek), Executive Director of theCouncil of Energy Resource Tribes (CERT) andNCAIED board member presented the award toEchohawk. During his award presentation speech,Lester spoke of the profound impact thatEchohawk and NARF’s leadership had on tribalsovereignty and economic development success inIndian Country over the last 36 years. It was alsonoted by Lester that John Echohawk has alsoserved as a board member of NCAIED for morethan a decade. He has been a tireless advocate fortribal sovereignty and the opportunities it bringsto tribes and Indian Country for economic self-sufficiency and the creation of sustainable tribaleconomies. Echohawk and NARF received a touching standing ovation from NCAIED member-ship and Indian and non-Indian business leadersin attendance. Five other Indian and non-Indianbusiness and tribal leaders were also honored atthe Res 2007 Awards. ❂

John Echohawk & NARF Honoredby National Indian Business Leaders

Fred Cantu, Chief of the Saginaw ChippewaTribe of Michigan, was elected to the NARF Boardof Directors to fill the vacancy left by JaimeBarrientoz who completed his three two-yearterms on the Board. Tribal Chief Fred Cantu, Jr.,has been serving on Tribal Council for the lastthree and a half years. The last year and a halfbeing the chief and one year as the Tribal Chaplin.Chief Cantu serves along side his wife Denise, whois on the Eldership for the United Tribes for Christwhich is an organization based out of OkalahomaCity. Chief Cantu is also a former SaginawChippewa Fire Department Chief, serving for eightyears, and has extensive experience in the tribalgaming operation. Chief Cantu and his wifeDenise are also Elders at the Potter’s HouseFamily Worship Center and live on the reservationwith their three children. The NARF Board ofDirectors and the NARF staff look forward to working with Chief Cantu.

Keith Anderson, Secretary/Treasurer and member of the Shakopee Mdewakanton SiouxCommunity in Minnesota, was elected to theNARF Board of Directors to fill the vacancy left byKarlene Hunter who completed her three two-yearterms on the Board. Keith was elected to the office of Secretary/Treasurer of the ShakopeeMdewakanton Sioux Community in January 2004.Prior to serving as Secretary/Treasurer, he servedon the Little Six Board of Directors as Chairmanfor five years and as a Board member for two years.The Little Six Inc. Board of Directors consisted ofShakopee Mdewakanton Sioux Community tribalmembers elected to two-year terms. The Boardoversaw the management of the ShakopeeMdewakanton Sioux Community gaming enterprises,Mystic Lake Casino and Little Six Casino. Keithpreviously worked for Rosemount Engineering asa draftsman in aerospace instrumentation design,and also as a draftsman for Target in the area ofstore design and store fixture design. The NARFBoard of Directors and the NARF staff look forwardto working with Mr. Anderson.


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• Little Traverse Bay Band of Odawa Indians

• Mashantucket Pequot

• Mille Lacs Band of Ojibwe

• Muckleshoot Tribe

• Oneida Tribe of Indians of Wisconsin

• Pamunkey Indian Reservation

• Prairie Band of Potawatomi Nation

• San Manuel Band of Mission Indians

• Seminole Tribe of Florida

• Siletz Tribe

• Southern Ute Indian Tribe

• Viejas Band of Kumeyaay Indians

It has been made abundantly clear that non-Indian philanthropy can no longer sustainNARF’s work. Federal funds for specific projectsare also being reduced at drastic rates. Our ability to provide legal advocacy in a wide varietyof areas such as religious freedom, the TribalSupreme Court Project, tribal recognition,human rights, trust responsibility, tribal waterrights, Indian Child Welfare Act, and on Alaskasovereignty issues has been compromised.NARF is now turning to the tribes to provide thiscrucial funding to continue our legal advocacyon behalf of Indian Country. It is an honor to list

those Tribes and Native organizations who havechosen to share their good fortunes with theNative American Rights Fund and the thousandsof Indian clients we have served. The generosityof Tribes is crucial in NARF’s struggle to ensure the future of all Native Americans. Weencourage other Tribes to become contributorsand partners with NARF in fighting for justice forour people and in keeping the vision of ourancestors alive. We thank the following tribesand Native organizations for their recent supportsince October 1, 2006:

CALLING TRIBES TO ACTION!


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About the LibraryThe National Indian Law Library (NILL) located

at the Native American Rights Fund in Boulder,Colorado is a national public library serving peopleacross the United States. Over the past thirty-threeyears NILL has collected nearly 9,000 resourcematerials that relate to federal Indian and triballaw. The Library’s holdings include the largest collection of tribal codes, ordinances and constitu-tions in the United States; legal pleadings frommajor American Indian cases; law review articleson Indian law topics; handbooks; conference materials; and government documents.

Library ServicesInformation access and delivery: Library users

can access the searchable catalog whichincludes bibliographic descriptions of the libraryholdings by going directly to: http://www.narf.org/nill/index.htm or by accessing the catalog through the National Indian LawLibrary/Catalog link on the Native AmericanRights Fund website at www.narf.org. Once relevant materials are identified, library patronscan then choose to request copies or borrowmaterials through interlibrary loan for a nominal fee.

Research assistance: In addition to making itscatalog and extensive collection available to thepublic, the National Indian Law Library providesreference and research assistance relating toIndian law and tribal law. The library offers freeassistance as well as cutomized research for anominal fee.

Keep up with changes in Indian law withNILL’s Indian Law Bulletins: The Indian LawBulletins are published by NILL in an effort keepNARF and the public informed about Indian lawdevelopments. NILL publishes timely bulletinscovering new Indian law cases, U.S. regulatoryaction, law review articles, and news on its website. (See: http://www.narf.org/nill/bulletins/ilb.htm) New bulletins are published on a regular basis, usually every week and olderinformation is moved to the bulletin archive

pages. When new information is published,NILL sends out brief announcements and a linkto the newly revised bulletin page via e-mail.Send an e-mail to David Selden at [email protected] if you would like to subscribe to theIndian Law Bulletin service. The service is freeof charge!

Support the Library: The National Indian LawLibrary is unique in that it serves the public butis not supported by local or federal tax revenue.NILL is a project of the Native American RightsFund and relies on private contributions frompeople like you. For information on how you cansupport the library or become a sponsor of a special project, please contact David Selden,the Law Librarian at 303-447-8760 [email protected] For more information aboutNILL, visit: http://www.narf.org/nill/index.htmLocal patrons can visit the library at 1522Broadway, Boulder, Colorado.❂

Your Information Partner!



THE NATIVE AMERICAN RIGHTS FUND

NARF Annual Report. This is NARF’s major report onits programs and activities. The Annual Report is distributed to foundations, major contributors, certainfederal and state agencies, tribal clients, NativeAmerican organizations, and to others upon request.Ray Ramirez Editor, [email protected].

The NARF Legal Review is published biannually by theNative American Rights Fund. Third class postage paidat Boulder, Colorado. Ray Ramirez, Editor,[email protected]. There is no charge for subscriptions,however, contributions are appreciated.

Tax Status. The Native American Rights Fund is a non-profit, charitable organization incorporated in 1971under the laws of the District of Columbia. NARF isexempt from federal income tax under the provisions ofSection 501 C (3) of the Internal Revenue Code, andcontributions to NARF are tax deductible. The Internal

Revenue Service has ruled that NARF is not a “privatefoundation” as defined in Section 509(a) of the InternalRevenue Code.

Main Office:Native American Rights Fund506 Broadway, Boulder, Colorado 80302 (303-447-8760) (FAX 303-443-7776)http://www.narf.org

Washington, D.C. Office:Native American Rights Fund1712 N Street, NW, Washington, D.C. 20036 (202-785-4166) (FAX 202-822-0068)

Alaska Office:Native American Rights Fund420 L Street, Suite 505, Anchorage, Alaska 99501 (907-276-0680) (FAX 907-276-2466)

The Native American Rights Fund (NARF) wasfounded in 1970 to address the need for legal assis-tance on the major issues facing Indian country. The critical Indian issues of survival of the tribes andNative American people are not new, but are thesame issues of survival that have merely evolved overthe centuries. As NARF is in its thirty-sixth year ofexistence, it can be acknowledged that many of thegains achieved in Indian country over those years aredirectly attributable to the efforts and commitmentof the present and past clients and members ofNARF’s Board and staff. However, no matter howmany gains have been achieved, NARF is stilladdressing the same basic issues that caused NARFto be founded originally. Since the inception of thisNation, there has been a systematic attack on tribalrights that continues to this day. For every victory, anew challenge to tribal sovereignty arises from stateand local governments, Congress, or the courts. Thecontinuing lack of understanding, and in some caseslack of respect, for the sovereign attributes of Indiannations has made it necessary for NARF to continuefighting.

NARF strives to protect the most important rightsof Indian people within the limit of availableresources. To achieve this goal, NARF’s Board ofDirectors defined five priority areas for NARF’s work:(1) the preservation of tribal existence; (2) the pro-tection of tribal natural resources; (3) the promotionof human rights; (4) the accountability of govern-ments to Native Americans; and (5) the developmentof Indian law and educating the public about Indianrights, laws, and issues.

Requests for legal assistance should be addressedto NARF’s main office at 1506 Broadway, Boulder,Colorado 80302. NARF’s clients are expected to pay whatever they can toward the costs of legal representation.

NARF’s success could not have been achieved with-out the financial support that we have received fromthroughout the nation. Your participation makes abig difference in our ability to continue to meet ever-increasing needs of impoverished Indian tribes,groups and individuals. The support needed to sustain our nationwide program requires your continued assistance.

NATIVE AMERICAN RIGHTS FUND BOARD OF DIRECTORS

John Gonzales, Chairman ............................................................................... San Ildefonso PuebloPaul Ninham, Vice-Chairman .............................................................................. Wisconsin OneidaKeith Anderson ............................................................ Shakopee Mdewakanton Sioux Community Andrew J. Bowers, Jr. ................................................................................Seminole Tribe of FloridaFred Cantu, Jr. ...................................................................................................... Saginaw ChippewaDelia Carlyle .......................................................................................... Ak Chin Indian CommunityElbridge Coochise ...................................................................................................................... HopiBilly Frank .......................................................................................................................... NisquallyJim Gray .................................................................................................................................... OsageKunani Nihipali ........................................................................................................ Native HawaiianLydia Olympic .................................................................................................................. Yupik/AleutAnthony Pico ................................................................................ Viejas Band of Kumeyaay IndiansWoody Widmark ................................................................................................................ Sitka TribeExecutive Director: John E. Echohawk ................................................................................ Pawnee

NARF LEGAL REVIEW • VOLUME 32, NO.1 • WINTER/SPRING 2007

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