United States v. Sandoval

United States v. Sandoval, 231 U.S. 28 (1913), was a United States Supreme Court case deciding whether the federal government's law prohibiting liquor on the land of Santa Clara Pueblo impermissibly infringed on the State of New Mexico's police power under the equal footing doctrine. In a unanimous decision, the Court upheld the law and Congress's ability to recognize and regulate tribes. Citing broad congressional authority in Kagama, recognition of tribes subject to the guardianship of the federal government falls on Congress, not the Court, as long as recognition is not "arbitrary" and actually reflects "distinctly Indian communities." The Supreme Court held the Pueblos to be dependent Indian communities.