Property Law Developments—Joseph William Singer

The Ninth Circuit has held that the Kawaiisu (a tribe that is not recognized by the federal government) cannot assert title to its ancestral lands because it failed to file a claim under the California Land Claims by the 1851 deadline. Failure to do so, the court held, extinguished tribal title, apparently without compensation. Nor could it base its claim on a later treaty because that treaty (like other treaties with California tribes) was never ratified by Congress. Robinson v. Jewell, 2015 U.S. App. LEXIS 10446 (9th Cir. 2015).