Cayuga Indian Nation of New York v Pataki

Cayuga Indian Nation of New York v. Pataki, 413 F.3d 266 (2d Cir. 2005), is an important precedent in the United States Court of Appeals for the Second Circuit. Applying the U.S. Supreme Court's recent ruling in City of Sherrill v. Oneida Indian Nation, a divided panel held that the equitable doctrine of laches bars all tribal land claims sounding in ejectment or trespass. Since the ruling, no tribal plaintiff has overcome the laches defense in a land claim in the Second circuit. The ruling was the culmination of a two-decade-long litigation in the District Court for the Northern District of New New York before Judge Neal Peters McCurn. The court rejected the state's arguments that damages should be limited to the fair market value of the land at the time of the transaction, without pre-judgement interest (the approximate method used by the Indian Claims Commission for statutory claims against the federal government). That same year, the court rejected ejectment as a remedy, thus ensuring that the Cayuga would be unable to recover possession of the lands.