SCLC #727 · 1867 New York Indians · Seneca tax-sale occupancy proviso void
The New York Indians, 72 U.S. 761 (May 16, 1867) held that New York’s 1841 tax act authorizing sale of Seneca reservation land did not save the taxes merely because a proviso said sale would not affect Indian occupancy — the land itself was assessed and sold, embarrassing protected possession under Canandaigua. Taxes voided on Buffalo Creek, Alleghany, and Cattaraugus; Buffalo Creek taxation in 1840–43 was premature while the possession/removal period had not expired. 1857 NY prospective non-tax rule for the two retained reservations did not retroactively validate earlier titles.
Source: README. Craft: occupancy proviso ≠ treaty-safe tax title; three-reservation voiding ≠ all four; 1857 prospective rule ≠ retroactive cure.