In 1951, the Makah Tribe successfully challenges state regulation of their nets on the Hoko River. (The Hoko River runs into the Strait of Juan de Fuca on the north coast of the Olympic Peninsula about 15 miles east of Cape Flattery.)
The Ninth Circuit Court of appeals holds that "State regulation ... was not necessary for conservation purposes ... [and therefore] the State had no right to close the river to Indian net fishing."
Sources:
Cesare Marino, "History of Western Washington Since 1846," Handbook of North American Indians, Vol. 7: Northwest Coast (Washington, D.C.: Smithsonian Institution, 1990), 176.
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