25 U.S.C. § 85
Section 85 · Contracts relating to tribal funds or property
Amended 1 time on record
Applied in 3 court decisions — leading case Western Shoshone Business Council ex rel. Western Shoshone Tribe of the Duck Valley Reservation v. Babbitt (1993)
Most recently applied in 49 F. Supp. 2d 1169 - Landmark Golf Ltd. Partnership v. Las Vegas Paiute Tribe (March 1999)
How often courts cite this section
Court decisions citing this, by year.Markers show enactment, consequential amendments, and circuit splits over this section — watch for a citation surge after a change or a disagreement. The dip in the last several years is a data-coverage gap, not a real trend — our corpus holds fewer opinions from the most recent years, so recent citations are undercounted.
No contract made with any Indian, where such contract relates to the tribal funds or property in the hands of the United States, shall be valid, nor shall any payment for services rendered in relation thereto be made unless the consent of the United States has previously been given.