Johnson v. M'Intosh

In this 1823 unanimous decision, Chief Justice John Marshall ruled that private citizens could not purchase land directly from Native American tribes. The case arose from competing claims: one derived from a 1773 Piankeshaw tribal sale, the other from a U.S. government land patent. Marshall's opinion established the "discovery doctrine," holding that European nations gained sovereignty over lands they explored, reducing Indigenous peoples to occupants without the power to sell. The ruling became foundational to U.S. property law and Indigenous land rights jurisprudence.