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Arizona v. Navajo Nation

599 U.S. 555 · 2023 · Supreme Court of the United States

Holding

The Court held 5-4 (Kavanaugh, J.) that although the 1868 treaty establishing the Navajo Reservation reserved the water necessary to accomplish the reservation's purpose, it did not impose an affirmative, judicially enforceable duty on the United States to take steps to secure water for the Navajo Nation, so the Nation's breach-of-trust claim failed.

"reserved necessary water to accomplish the purpose of the Navajo Reservation" — Holding line published with the slip opinion, supremecourt.gov, Arizona v. Navajo Nation, No. 21-1484

Why it matters for settlements

Reaffirms that Winters rights exist for the Navajo Reservation while foreclosing a treaty-based trust claim to force the United States to assess or develop water supplies, pushing tribes toward adjudication and settlement.

Read the primary record (supremecourt.gov)

Consolidated with Department of the Interior v. Navajo Nation (No. 22-51). supremecourt.gov's table lists the decision date as 6/22/23; Oyez's API reports June 21, 2023. The supremecourt.gov date is treated as authoritative. Justia's /cases/federal/us/599/555/ path returned 404 this session and is therefore not cited.

Sources

supremecourt.gov Opinions of the Court, OT2022 table (docket 21-1484, decided 6/22/23, citation 599 U.S. 555, opinion PDF link) (supremecourt.gov, retrieved 2026-09-01)
supremecourt.gov opinion PDF (fetched; PDF content returned) (supremecourt.gov, retrieved 2026-09-01)
Oyez API (vote split 5-4, majority author Kavanaugh; cross-check) (api.oyez.org, retrieved 2026-09-01)