MAY 17, 1906


With competition for Alaskan land increasing in the late 1800s, disputes between miners, resource developers, and Alaska Native people arose leading to litigation.  Two early cases [U.S. v. Berrigan,              2 Alaska 443 (1905) and U.S. v. Cadzow, 5 Alaska 125 (1914)] held that non-Natives could not acquire land from Indian people without Federal consent.  In essence, the courts recognized Alaska Native peoples’ aboriginal claims to their land.  In 1906, Congress adopted the Alaska Native Allotment Act (ANAA) which entitled Alaska Natives to restricted land entitlements of up to 160 acres of unappropriated, non-mineral land.  Today, most remaining allotments (some 15,000) are mostly around villages and in hunting and fishing use areas.  While the ANAA was superseded by the Alaska Native Claims Settlement Act in 1971, ANAA allotment lands remain Native Alaskan land in restricted or trust status and are under tribal jurisdiction.

Source:  “Early Alaska Native Land Cases and Acts,” Relocate Kivalina, 5/30/2013.  Retrieved 6/30/2019, 
Photo:  Author unknown, circa 1902-1904.  Courtesy Elmer E. Rasmuson Library, University of Alaska Fairbanks.  Native Voices, NIH.   Public Domain in U.S.:  Pre 1/1/1925.  Public Domain elsewhere where copyright term is author’s life plus 70 years or less.

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