Administrative Law 5
6. Yes. In the language of the court, “Congress could validly delegate such authority to a reservation’s
tribal council. The independent authority of Indian tribes over matters that affect the internal and
social relations of tribal life is sufficient to protect Congress’ decision to vest in tribal councils this
portion of its own authority ‘to regulate Commerce…with the Indian tribes’ under Art. I. It is an
important aspect of this case that Indian tribes are unique aggregations possessing attributes of
sovereignty over both their members and their territory; they are ‘a separate people’ possessing ‘the
power of regulating their internal and social relations….’”
“[W]hen Congress, delegated its authority to control the introduction of alcoholic beverages
into Indian country, it did so to entities which possess a certain degree of independent authority
over matters that affect the internal and social relations of tribal life. Clearly the distribution and use
of intoxicants is just such a matter.”
“In holding that the authority of tribal courts could extend over non-Indians, insofar as
concerned their transactions on a reservation with Indians, we stated: ‘It is immaterial that
respondent is not an Indian. He was on the Reservation and the transaction with an Indian took
place there.’ The cases in this Court have consistently guarded the authority of Indian governments
over their Reservations. Congress recognized this authority in the Navajos in the Treaty of 1868,
and has done so ever since. If this power is to be taken away from them, it is for Congress to do it.”
7. The court held that the public defenders lacked standing to challenge the sentencing guidelines.
“[P]laintiffs have failed to meet the threshold, constitutional requirement of injury in fact. It is not
possible to ‘find’ constitutional standing for two reasons. First, and foremost, the type of injury or
harm alleged by these plaintiffs, who are in essence a collective body of criminal lawyers, cannot
be distinguished from the sort of harm or injury absorbed by any legal specialist or group of
8. Wilson was arguing both due process and unlawful delegation. The unlawful delegation argument
was that the decision-maker in this case was a private corporation performing a public function and
they had an economic interest in deciding to boot the car. The heart of the due process argument
was his contention that he had a right to pre-boot hearing. The court did not address the delegation
question, but you might want to raise it in the context of the movement toward private jails. On writ