Cite as: 523 U. S. 696 (1998)
Opinion of the Court
App. 286. It follows, the District Court next said, that the tax approved for the reservation proper in 1977, see supra, at 703, covered the strip as well, and the Interior Department had erred in ever opining otherwise, App. 286. As to Westmoreland's operations on the strip, the District Court further stated, the Crow tax had been modified by the 1982 agreement amending the lease. Id., at 287; see supra, at 704-705. That 1982 Tribe-Westmoreland accord controlled, the District Court concluded, rendering the amount deposited payable to the Tribe, and not to Westmoreland. Shortly thereafter, the District Court ordered distribution of funds in its registry to the United States, as trustee for the Tribe. App. 288-291.
Having secured exclusively for the Tribe's benefit West-moreland's post-1982 tax payments once held in the District Court's registry, the United States and the Tribe commenced the fray now before us. Filing amended complaints against Montana and Big Horn County, they invoked theories of assumpsit and constructive trust in support of prayers to recover some $58.2 million in state and county taxes paid by Westmoreland prior to the 1983 and 1987 orders directing deposits into the court's registry. App. to Pet. for Cert. 243-260. These complaints alleged that, because the State and Big Horn County had collected taxes from Westmoreland in violation of federal law, it would be unjust and inequitable to allow them to retain the funds. In "equity and good conscience," the United States and the Tribe urged, Montana should pay over for the benefit of the Tribe all moneys illegally collected, together with interest thereon. See id., at 249-250, 258-259.7 Neither the Tribe nor the United States requested, as additional or alternate relief, recovery for the
7 Specifically, the amended complaints sought all moneys paid as severance taxes from 1975 through 1983, and as gross proceeds taxes from 1975 through 1988, together with prejudgment interest. App. to Pet. for Cert. 250-251, 259.
707
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