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24 After misreading the Navajo’s request and applying the wrong analytical framework, the Court errs in one last way. It reaches the wrong result even under this Court’s Tucker Acts framework. The second step of the analysis—using “trust principles” to sort out the damages the United States owes, Navajo II, 556 U. S., at 301—clearly has no purchase in this context. (Another tell that the Tucker Acts framework itself has no purchase.) But what about the first step? Historically, this Court’s cases have distinguished between regulatory schemes that create “bare trusts” (that cannot sustain actions for damages) and a “conventional” trust (that can make the government “liable in damages for breach” under the Tucker Acts). White Mountain Apache Tribe, 537 U. S., at 473–474; see. A close look at those decisions suggests that, even under them, the Tribe’s claim should be allowed to proceed.

Take Mitchell II as an example. There, this Court allowed a claim for money damages relating to the mismanagement of tribal forests. On what basis? A patchwork of statutes and regulations, along with some assorted representations by the Department of the Interior. 463 U. S., at 219–224. In holding this showing sufficient to support an action for money damages, this Court observed that, “where the Federal Government takes on or has control” of property belonging to a Tribe, the necessary “fiduciary relationship normally exists … even though nothing is said expressly” about “a trust or fiduciary connection.” Id., at 225 (internal quotation marks omitted). Further, where the federal government has “full responsibility” to manage a resource or “elaborate control” over that resource, the requisite “fiduciary relationship necessarily arises.” Id., at 224–225 (emphasis added). Statements by the United States “recogniz[ing]” a fiduciary duty, the Court explained, can help confirm as much too. Id., at 224.

Consider White Mountain Apache Tribe as well. There,