Lone Wolf was a Kiowa Indian chief, living in the Indian Territory created by the Medicine Lodge Treaty of 1867. A provision in the treaty required that three-fourths of the adult males in each of the Kiowa, Apache, and Comanche tribes agree to subsequent changes to the terms of the treaty. In 1892, Congress attempted to alter the reservation lands granted to the tribes.
In enacting the relevant legislation, Congress substantively changed the terms of the treaty and opened 2 million acres of reservation lands to settlement by non-Indians. Lone Wolf filed a complaint on behalf of the three tribes in the Supreme Court of the District of Columbia, alleging that Congress' change violated the 1867 treaty. That court dismissed the case. The United States Court of Appeals for the District of Columbia Circuit affirmed the decision. Lone Wolf and the tribes appealed to the Supreme Court.
In a unanimous decision, the Court affirmed the Court of Appeals and upheld the Congressional action.
The final ruling effectively gave Congress absolute power over the tribal holdings.
This decision was based on the idea that Indians held dependent status to the United States government. Calling Native Americans “the wards of the nation,” White stated that “from their very weakness and helplessness, so largely due to the course of dealing of the Federal government with them and the treaties in which it has been promised, there arises the duty of protection, and with it the power.”
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