416
Opinion of the Court
is concerned, than any judgment entered only as a compromise of the parties." Id., at 505-506 (citations omitted).
The State parties, perhaps recognizing the infirmity of their argument as a matter of standard preclusion doctrine, assert that common-law principles of issue preclusion do not apply in the special context of Indian land claims. Instead, they argue, § 22 of the Indian Claims Commission Act created a special regime of "statutory preclusion." 5 According to the State parties, the payment of a Commission judgment for claims to aboriginal or trust lands automatically and universally extinguishes title to the Indian lands upon which the claim is based and creates a statutory bar to further assertion of claims against either the United States or third parties based on the extinguished title. The State parties point to several decisions of the Ninth Circuit in support of this contention. See Reply Brief for State Parties 17 (citing United States v. Pend Oreille Pub. Util. Dist. No. 1, 926 F. 2d 1502 (CA9 1991)); Reply Brief for State Parties 15 (citing United States v. Dann, 873 F. 2d 1189 (CA9 1989)); Reply Brief for State Parties 11 (citing United States v. Gemmill, 535 F. 2d 1145 (CA9 1976)).
We need not decide whether, in the distinctive context of the Indian Claims Commission Act, some consent judgments
5 Section 22 provided: "(a) When the report of the Commission determining any claimant to be entitled to recover has been filed with Congress, such report shall have the effect of a final judgment of the Court of Claims, and there is authorized to be appropriated such sums as are necessary to pay the final determination of the Commission.
"The payment of any claim, after its determination in accordance with this chapter, shall be a full discharge of the United States of all claims and demands touching any of the matters involved in the controversy.
"(b) A final determination against a claimant made and reported in accordance with this chapter shall forever bar any further claim or demand against the United States arising out of the matter involved in the controversy." 25 U. S. C. § 70u (1976 ed.).
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