Hollowbreast – The Lodge Approach

Northern Cheyenne Tribe v. Hollowbreast

Northern Cheyenne Tribe v. Hollowbreast, a U.S. Supreme Court case from 1976. This case was about who owns the valuable minerals—such as coal, oil, and gas—under the Northern Cheyenne Reservation in Montana.

In 1926, Congress passed the Northern Cheyenne Allotment Act. The law said these minerals would benefit the Tribe, but it also included confusing language about what would happen after 50 years. Later, in the 1970s, Congress amended the law to keep the mineral rights with the Tribe “in perpetuity,” unless individual landowners had already gained a legal right to them.

The Supreme Court ruled in 1976 that the original law did not give individual allottees like Hollowbreast a guaranteed right to the minerals. Instead, the Court said Congress meant to keep those mineral rights with the Northern Cheyenne Tribe for the benefit of the whole community. This decision strengthened the Tribe’s control over its land and natural resources.

Lesson Plans

This 3-day unit for Grades 3-4 on the Northern Cheyenne vs. Hollowbreast Supreme Court ruling (1976 Montana case affirming tribal jurisdiction over reservation allotments) is designed for Montana teachers. The lessons meet Montana IEFA Essential Understandings (EU1: Homelands, EU3: Governments, EU5: Contemporary Issues) and OPI standards. No prior knowledge is needed; each day builds logically for Northern Cheyenne homelands or statewide classrooms.

Resources

We will be populating this section with more resources in the coming weeks.

May 19, 2026 - 50th Celebration

May 19th is observed on the Northern Cheyenne Reservation as “Hollowbreast Case” Day, marking the U.S. Supreme Court decision in Northern Cheyenne Tribe v. Hollowbreast, which centered on tribal ownership of coal and other mineral rights on the reservation.

What happened

•In 1926, federal law reserved coal and other minerals on Northern Cheyenne allotments for the tribe, with a clause that they would pass to individual allottees after 50 years.

•In 1976, the Supreme Court’s Hollowbreast decision held that Congress later changed that arrangement so the mineral rights stayed with the tribe rather than reverting to individuals, which significantly affected control of valuable coal reserves.

•The Northern Cheyenne Nation lists May 19 as “Hollowbreast Case” on its holiday calendar, commemorating this legal affirmation of tribal mineral ownership.