American Federalism
and Intergovernmental Innovation
in State-Tribal Relations
Erich Steinman
University of Washington
Relations between American Indian tribes and state governments are poorly understood; they have
been inaccurately portrayed as exclusively or increasingly conjlictual. This study balances such perceptions
and identifies constructive patterns of state-tribal relations that developed between 1970 and 2003.
President Richard M. Nixon's 1970 policy ofIndian self-determination affirmed Indian tribes' survival;
yet it failed, in the context of tribes' extraconstitutional status, to clarify their relationship to state
governments. Since then, entrepreneurial tribal leaders have asserted sovereign governmental status
while advocating practical and substantive cooperation with state governments in place of adversarial
and legalistic relations. The partial success of these efforts has produced new intergovernmental
mechanisms and the development of state-tribal relations as an ongoing and increasingly normalized
category of intergovernmental relations, even amidst conflict over tribal gaming and a shifting political
and legal environment.
American Indian tribes and state governments have long been engaged
in conflict over the control of Indian reservation land and residents. Most
commonly, tribes have struggled to maintain the exclusive control they
originally enjoyed at the time of each reservation's creation by the federal
government. As one group of legal scholars observes, "One of the clearest
and most persistent themes involving Indian sovereignty has been the
continuous struggle by the states to assert greater control over Indian
reservations, either at the expense of the federal or tribal governments."
1
Similarly, others note: "Exercises of state power have continually come into
conflict with tribal self-government. . . . In case after case, states and
municipal governments as subdivisions of the states, have stretched to assert
their governmental authority over Indians and their territory."
2
Because of
state encroachments, states have been understood as the "deadliest enemies"
of tribes, as famously noted by the U.S. Supreme Court in 1886.
3
Conflict between tribes and states reflects the federalist division of powers
regarding Indian affairs as declared in the United States Constitution. Since
AUTHOR'S NOTE: I wish to thank John Kincaid for editorial assistance, the three anonymous reviewers
for their helpful comments and suggestions, and Katherine Friedman, Gary Hamilton, Alexandra Harmon,
Debra Minkoff, David Olson, Alan Parker, John Skrentny, and Bartholomew H. Sparrow for advice on the
overall project. I would also like to thank the many individuals who agreed to be interviewed for this
study.
'Robert N. Clinton, Nelljessup Newton, and Monroe E. Price, American Indian IJIW. Cases and Materials
(Charlotlesville, VA: Michie Company, 1991), p. 493.
2
David Getches, "Negotiated Sovereignty: Intergovernmental Agreements with American Indian Tribes
as Models for Expanding Self-Government," Review of Constitutional Studies 1 (1, 1993): 136.
"U.S. v. Kagama,U% U.S. 375 (1886).
© Publius: The Journal of Federalism 34:2 (Spring 2004)
95
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