Indian Nations Law Update - July 2022 - Sovereign Immunity: Public Sector Government - United States (2022)

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In Oklahoma v. Castro-Huerta, 2022 WL 2334307 (US2022), the Supreme Court addressed the General Crimes Act, 18U.S.C. 1152, which, "[e]xcept as otherwise expressly providedby law," extends the "general laws of the UnitedStates" to "the Indian country." The State ofOklahoma prosecuted and convicted Castro-Huerta, a non-Indianresiding in Tulsa, for criminal neglect of his step-daughter, aCherokee Indian. Castro-Huerta challenged his conviction on theground that, pursuant to the Supreme Court's 2020 holding inMcGirt v. Oklahoma, the site of the offense was Indiancountry, and the state lacked jurisdiction under the General CrimesAct. The Supreme Court disagreed, holding that the state andfederal governments had concurrent jurisdiction over offensescommitted in Indian country by non-Indians against Indians:"Indian country is part of the State, not separate from theState. To be sure, under this Court's precedents, federal lawmay preempt that state jurisdiction in certain circumstances. Butotherwise, as a matter of state sovereignty, a State hasjurisdiction over all of its territory, including Indian country.... Under the Court's precedents, as we will explain, aState's jurisdiction in Indian country may be preempted (i) byfederal law under ordinary principles of federal preemption, or(ii) when the exercise of state jurisdiction would unlawfullyinfringe on tribal self-government. ... [T]he General Crimes Actdoes not say that Indian country is equivalent to a federal enclavefor jurisdictional purposes. Nor does the Act say that federaljurisdiction is exclusive in Indian country, or that statejurisdiction is preempted in Indian country. ... Under the GeneralCrimes Act, therefore, both the Federal Government and the Statehave concurrent jurisdiction to prosecute crimes committed inIndian country. The General Crimes Act does not preempt stateauthority to prosecute Castro-Huerta's crime. ... Moreover, ifCastro-Huerta's interpretation of the General Crimes Act werecorrect, then the Act would preclude States from prosecuting anycrimes in Indian country—presumably even those crimescommitted by non-Indians against non-Indians—just as Statesordinarily cannot prosecute crimes committed in federal enclaves.But this Court has long held that States may prosecute crimescommitted by non-Indians against non-Indians in Indiancountry." The four dissenting justices, in an opinion byJustice Gorsuch, pointed out that the majority ignored over twohundred years of jurisdictional congressional enactments that werebased on the principle that states lacked jurisdiction in Indiancountry unless expressly granted by Congress.

In Ysleta Del Sur Pueblo v. Texas, 142 S.Ct. 1929 (US2022), the Ysleta del Sur Pueblo and Alabama and Coushatta IndianTribes of Texas Restoration Act of 1987 (Restoration Act) had theeffect of restoring those tribes to recognition. At the same time,the Restoration Act prohibited as a matter of federal law "allgaming activities which are prohibited by the laws of the State ofTexas," while cautioning that the Act should not be"construed as a grant of civil or criminal regulatoryjurisdiction to the State of Texas." After Congress enactedthe Indian Gaming Regulatory Act of 1988 (IGRA),the Ysleta del Sur Pueblo commenced efforts to develop and conducta gaming enterprise on its reservation, triggering years oflitigation with the State of Texas. In 2021, the Fifth CircuitCourt of Appeals rejected the Tribe's argument that the IGRA,not the Restoration Act, controlled, but the U.S. Supreme Court, ina 5-4 decision authored by Justice Gorsuch, reversed: "[A]full look at the [Restoration Act's] structure suggests a setof simple and coherent commands. In subsection (a), Congresseffectively federalized and applied to tribal lands those statelaws that prohibit or absolutely ban a particular gaming activity.In subsection (b), Congress explained that it was not authorizingthe application of Texas's gaming regulations on tribal lands.In subsection (c), Congress granted federal courts jurisdiction toentertain claims by Texas that the Tribe has violated subsection(a). Texas's competing interpretation of the law rendersindividual statutory terms duplicative and whole provisions withoutwork to perform. ... Even if fair questions remain after a look atthe ordinary meaning of the statutory terms before us, importantcontextual clues resolve them. Recall that Congress passed the Actjust six months after this Court handed down Cabazon. See PartI–B, supra. In that decision, the Court interpreted PublicLaw 280 to mean that only 'prohibitory' state gaming lawscould be applied on the Indian lands in question, not state'regulatory' gaming laws. The Court then proceeded to holdthat California bingo laws—laws materially identical to theTexas bingo laws before us today—fell on the regulatory sideof the ledger. Just like Texas today, California heavily regulatedbingo, allowing it only in certain circumstances (usually forcharity). Just like Texas, California criminalized violations ofits rules. Compare Cabazon, 480 U.S. at 205, 107 S.Ct. 1083, withTex. Occ. Code Ann. § 2001.551. Still, because Californiapermitted some forms of bingo, the Court concluded that meantCalifornia did not prohibit, but only regulated, the game. Cabazon,480 U.S. at 211, 107 S.Ct. 1083. ... For us, that clinches thecase. This Court generally assumes that, when Congress enactsstatutes, it is aware of this Court's relevant precedents. ...And at the time Congress adopted the Restoration Act, Cabazon wasnot only a relevant precedent concerning Indian gaming; it was theprecedent."

In Denezpi v. United States, 2022 WL 2111348 (U.S.2022), a Bureau of Indian Affairs (BIA) officer against Denezpi, amember of the Navajo Nation, charging Denezpi with three crimesalleged to have occurred at a house located within the Ute MountainUte Reservation: assault and battery, in violation of 6 UteMountain Ute Code § 2; terroristic threats, in violation of 25C.F.R. § 11.402; and false imprisonment, in violation of 25C.F.R. § 11.404. The complaint was filed in one of the Courtsof Indian Offenses established under the Code of FederalRegulations (C.F.R. court) a court which for Indian tribes incertain parts of Indian country "where tribal courts have notbeen established." § 11.102. Denezpi pleaded guilty tothe assault and battery charge and was sentenced to timeserved—140 days' imprisonment. Six months later, afederal grand jury in the District of Colorado indicted Denezpi onone count of aggravated sexual abuse in Indian country, an offensecovered by the federal Major Crimes Act. Denezpi moved to dismissthe indictment, arguing that the Double JeopardyClause barred the consecutive prosecution. The District Courtdenied Denezpi's motion. Denezpi was convicted and sentenced to360 months' imprisonment. The Tenth Circuit affirmed and, inthe instant case, the United States Supreme Court affirmed theTenth Circuit's decision: "The Double Jeopardy Clauseprotects a person from being prosecuted twice 'for the sameoffense.' An offense defined by one sovereign is necessarilydifferent from an offense defined by another, even when theoffenses have identical elements. Thus, a person can besuccessively prosecuted for the two offenses without offending theClause. We have dubbed this the 'dual-sovereignty'doctrine. ... This case presents a twist on the usualdual-sovereignty scenario. The mine run of these cases involves twosovereigns, each enforcing its own law. This case, by contrast,arguably involves a single sovereign (the United States) thatenforced its own law (the Major Crimes Act) after having separatelyenforced the law of another sovereign (the Code of the Ute MountainUte Tribe). Petitioner contends that the second prosecutionviolated the Double Jeopardy Clause because the dual-sovereigntydoctrine requires that the offenses be both enacted and enforced byseparate sovereigns. ... We disagree. By its terms, the Clauseprohibits separate prosecutions for the same offense; it does notbar successive prosecutions by the same sovereign. So even assumingthat petitioner's first prosecutor exercised federal ratherthan tribal power, the second prosecution did not violate theConstitution's guarantee against double jeopardy.""Federal prosecutors tried Merle Denezpi twice for the samecrime. First, they charged him with violating a federal regulation.Then, they charged him with violating an overlapping federalstatute. Same defendant, same crime, same prosecuting authority.Yet according to the Court, the Double Jeopardy Clause has nothingto say about this case. How can that be? To justify its conclusion,the Court invokes the dual-sovereignty doctrine. For reasons I haveoffered previously, I believe that doctrine is at odds with thetext and original meaning of the Constitution. ... But even takingit at face value, the doctrine cannot sustain the Court'sconclusion."

In Hill v. Nunn, 2022 WL 2154997, Not reported inFederal Reporter (10th Cir. 2022), the Tenth Circuit Court ofAppeals rejected a state prisoner's argument that the statuteof limitations for his filing of a habeas corpus petitionchallenging the state court's jurisdiction should begin runningas of the date that the United States Supreme Court ruled inMcGirt v. Oklahoma, ... that the MuskogeeCreek reservation continued to exist: "A state prisoner mustfile a § 2254 petition within one year of the statecourt's judgment becoming final. See 28 U.S.C. §2244(d)(1). ... Hill's latest convictions became final on June12, 1991—when the 90-day period for seeking review in theUnited States Supreme Court expired. ... [A]bsent tolling,Hill's deadline for filing his habeas petition was April 24,1997. Hill did not file his petition until December 30, 2021. ...On appeal, Hill seems to argue that he is entitled to statutorytolling under 28 U.S.C. § 2244(d)(1)(C) until the date of theSupreme Court's decision in McGirt v. Oklahoma, 140 S.Ct. 2452 (2020) (holding that the territory in Oklahoma reservedfor the Creek Nation since the 19th century remains 'Indiancountry' for purposes of exclusive federal jurisdiction over'certain enumerated offenses' committed 'within theIndian country' by an 'Indian') (internal quotationsomitted). He also contends that, as applied here, AEDPA isunconstitutional because the state court lacked jurisdiction whenhe was prosecuted. ... Hill's first argument is unpersuasive.As both the magistrate judge and district court correctlyexplained, McGirt did not recognize a new constitutionalright. See In re White, No. 21-7062 (10th Cir. Dec. 13, 2021). Hillthus cannot rely on the date of McGirt's publication as thetriggering date for the limitations period. ... Hill's secondargument is also meritless. This is because, as the district courtnoted, ... a claim predicated on a convicting-court's lack ofsubject matter jurisdiction 'is subject to dismissal foruntimeliness.'"

In Grondal v. United States, 2022 WL 2112793 (9th Cir.2021), Evans, the owner of a 5.4% interest in a trust allotmentknown as MA-8 near the Confederated Tribes of Colville Reservation,obtained the consent of a majority of the other allottee interestholders to a lease of MA-8 for 25 years, with an option to renewfor an additional 25 years (Master Lease), for purposes ofoperating a campground. Campground residents organized as the MillBay Members Association (Mill Bay). BIA approved the lease in 1984.Upon Evans' death in 2003, Wapato Heritage LLC (Wapato)acquired Evans' interest. Evans, Wapato and Mill Bay allbelieved that Evans had renewed the lease for an additional 25years by sending a renewal notice to BIA but BIA informed Wapato in2009, before the expiration of the initial lease term that thenotice of renewal to BIA was ineffective because the lease requiredthat individual allottees (IA) also be given notice. Mill Bay andWapato contested the BIA's interpretation in court but lost.Grondal (Wapato's sublessee under the Master Lease) and MillBay filed a new suit seeking a declaratory judgment that wouldrecognize their right to remain on MA-8, naming as defendants thefractionated owners of MA-8 (IAs, Wapato Heritage, and the Tribe)as well as the BIA. BIA counterclaimed with a suit in trespass. Indefense, Wapato and Mill Bay asserted, for the first time, that BIAhad no standing to pursue trespass because M-8 had lost its truststatus in the early 20th century. In separate decisions, lowercourts dismissed the defendants' arguments and granted summaryjudgment in favor of BIA. The Ninth Circuit affirmed. On remand,the district court dismissed Wapato's cross-claims against theColville Tribes on grounds of sovereign immunity: "[T]heTribes did not waive their sovereign immunity to WapatoHeritage's cross-claims as to the 2009 and 2014 ReplacementLeases. Wapato Heritage went on the offensive by asserting thesecross-claims against the Tribes in answering the complaint filed byGrondal and Mill Bay. And the Tribes invoked their immunity fromsuit in two Rule 12(b)(1) motions to dismiss Wapato Heritage'scross-claims for lack of jurisdiction, which were granted.Considering this participation of the Tribes in the case, theyretained their sovereign immunity to Wapato Heritage'scross-claims and the district court did not need to rule on themerits of these cross-claims. See Quinault Indian Nation, 868 F.3dat 1097–98 (explaining that the scope of a tribal sovereignimmunity waiver is restricted by 'the nature and bounds of thedispute that the tribe put before the court'); Bodi, 832 F.3dat 1016–18 (holding that a tribe did not waive its tribalsovereign immunity to certain claims by removing a lawsuit tofederal court then moving to dismiss those claims for lack ofsubject-matter jurisdiction)."

In Cayuga Nation v. Parker, 2022 WL 1813882 (N.D.N.Y.2022), the Cayuga Nation of New York manufactured and soldcigarettes, without New York state tax stamps, at locations on theTribe reservation in New York. The Seneca-Cayuga Nation of Oklahomaowned real property on the Cayuga reservation, which it leased toMeyer who, in turn, subleased to Parker, a Cayuga tribal member.Parker began selling Native-manufactured tobacco products from thesite that did not display New York tax stamps. Cayuga Nationofficials sought to terminate Parker's business because it hadnot received authorizations required under tribal law. Afterpurchasing the property from the Seneca-Cayuga Nation, the CayugaNation shut down Parker's shop, confiscated his inventory andopened its own smoke shop. After Parker sought to open a new smokeshop at another location on the Cayuga reservation, the Tribe suedhim and related entities in federal court, alleging violations ofthe Racketeer Influenced and Corrupt Organizations Act (RICO),specifically asserting that the defendants were engaged in anunlawful scheme to co-opt the Nation's sovereign rights, erodeits business and customer base, and steal its revenues through thesale of "untaxed and unstamped cigarettes and marijuana, andvarious other merchandise" on the reservation. The Tribe hadpreviously filed an action in its tribal court. The Tribe moved fora preliminary injunction in federal court. The defendants moved todismiss for lack of jurisdiction. The court denied the motion todismiss and stayed the action pending the parties' notificationof the exhaustion of proceedings in Cayuga Nation Civil Court:"The Court ... concludes that these circumstances—thepresence of a proceeding in Cayuga Nation Civil Court, the concernabout the Nation Court's authority to enforce the injunction,and the scope of that injunction, the presence of a dispute betweenCayuga Nation and Parker, a member of the Cayuga Nation and ownerand operator of Pipekeepers, regarding the operation of acommercial business governed by the Ordinance on reservationland—militate in favor of the application of thetribal exhaustion rule."

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In the case of In re Juul Labs Product LiabilityLitigation, 2022 WL 1955678 (N.D.Cal. 2022), the Saint RegisMohawk Tribe (SRMT) and Grand Traverse Band of Ottawa and ChippewaIndians (Grand Traverse Band) sued entities involved in thedistribution of JUUL vaping products, contendingthat the defendants knowingly or negligently and deceptivelymarketed and promoted addictive and harmful JUUL products to theTribe and its members within the Tribe's territory geographicareas controlled and occupied by the Tribe and its members and thatSRMT suffered damages through lost productivity of the Tribe'smembers, increased administrative costs, lost opportunities for theTribe's community growth and self-determination, andsubstantial damages relating to its ability to govern itself, theTribe's members, and territory as a direct result ofDefendants' wrongful acts and omissions and that the defendantscreated a growing hazardous waste problem on SRMT's propertybecause of improperly disposed JUUL devices and other vapingproducts in its parks and on other tribal property. Variousdefendants moved to dismiss on various grounds, included theexemption from liability available to regulated businesses, failureto state a claim, lack of jurisdiction and deficiencies in theplaintiffs' pleadings. The Court dismissed Grand TraverseBand's claim based on the Michigan Consumer Protection act,permitted Grand Traverse Band to amend its negligence claim andotherwise denied the defendants' motions to dismiss: "Forpresent purposes, the allegations of injury to property made bySRMT and injury to business made by both Tribes are sufficient. Howclosely or directly connected those injuries are to the conduct ofdefendants is better determined on a complete record. Similarly,whether the expenditures the Tribal plaintiffs claim they incurredare sufficiently "extraordinary" and directly connectedto defendants' conduct to convince me to follow JudgePolster's reasoning and distinguish Judge Breyer's isbetter determined on a full evidentiary record."

In Kiowa and Comanche Tribe v. United States, 2022 WL1913436 (W.D. Okla. 2022), 160 acres within the Kiowa and ComancheReservation in Oklahoma was allotted to Tsalote, a Kiowa member in1901. In 2001, the allotment, as deeded by a member of the FortSill Apache Tribe (FSAT) to the FSAT. When FSAT sought to open acasino on the allotment, the Kiowa and Comanche tribes suedofficials of the FSAT under the doctrine of Ex Parte Young,contending that their permission was required for the acquisitionof land in trust for another tribe within their former reservationand that the proposed casino would violate the IndianGaming Regulatory Act and the Racketeering Influenced andCorrupt Organizations (RICO) Act. The court denied theplaintiff's motion for a temporary restraining order:"Plaintiffs' theory of liability under RICO rests upon thepremise that if FSAT, an 'enterprise,' runs the Casino, itwill be knowingly operating 'an illegal gambling business'and engaging in money laundering because the Casino is notauthorized under IGRA (and therefore also not authorized underOklahoma law). ... Plaintiffs have not shown a substantiallikelihood of success on their claim that FSAT's acquisition ofthe Tsalote Allotment was invalid or on their claim that operationof the Casino will violate IGRA. Plaintiffs therefore cannot show asubstantial likelihood that they could successfully show that theFSA Defendants' intent to open and operate the Casino amountsto a RICO conspiracy and agreement to conduct FSAT's affairs'through a pattern of racketeering activity.'"

In McKinsey & Co. v. Boyd, 2022 WL 1978735 (W.D.Wis. 2022), the Red Cliff Band of Lake Superior Chippewa (Band)sued McKinsey & Co (McKinsey) in Tribal Court, seeking to holdit accountable for consulting work with opioid companies and theensuing, resultant opioid epidemic on the Red Cliff Reservation.McKinsey sued in federal district court to enjoin the tribal courtlitigation and the district court granted McKinsey's motion forinjunctive relief on the ground that McKinsey's actions wereoutside the tribe's jurisdiction for purposes of the rule ofMontana v. United States and its secondexception to the general rule: "McKinsey has no offices on theRed Cliff Reservation nor anywhere else in Wisconsin; none of itsopioid-related engagements originated within the Reservation orthis state; and none of its consultants could have been based in anoffice there. ... Here, there is no suggestion that any activitytook place on tribal land. While defendants broadly argue thatMcKinsey's aid to the opioid industry contributed to addictionon the reservation, threatening the health of the tribe, that istoo attenuated to be considered 'conduct of non-Indians on feelands within its reservation.' Opioid addiction certainlyplagues tribal lands, along with the majority of the rest of thecountry, but McKinsey is being sued for advising pharmaceuticalcompanies selling opioids, who in turn manufacture, distribute andprescribe the use of these drugs to physicians, dentists andpatients throughout the country, arguably creating demand andaddiction that would not be there otherwise. However, defendants donot point to any action by plaintiff taking place on tribal land,and the court is skeptical that any such evidence exists givenMcKinsey's lack of ties to state of Wisconsin, much less theRed Cliff Tribe. Accordingly, the strong general rule against theexercise of tribal jurisdiction over non-tribe members plainlyapplies here."

In Pueblo of Pojoaque v. Biedscheid, 2022 WL 174920 4(D. N.M. 2022), Pena sued the Pueblo of Pojoaque (Tribe) in statecourt after he allegedly suffered injuries at the Tribe'sBuffalo Thunder's casino. The Tribe sued in federal court toenjoin the state court judge, Biedscheid, from hearing the case,arguing that the Indian Gaming Regulatory Act(IGRA) preempted state court jurisdiction. The federalcourt denied the Tribe's motion for summary judgment, holdingthat the Anti-Injunction Act, 28 U.S.C. § 2283, and theabstention doctrine of Younger v. Harris barred the Courtfrom issuing the requested injunction and rejecting the Tribe'sunderlying argument that fall within the scope of IGRA:"Simply because an accident occurs at a casino on Tribal landdoes not necessarily mean that the accident's victim is engagedin Class III gaming activity under IGRA. ... Because Pena was notparticipating in a Class III gaming activity when he fell,therefore, the tort claims arising from Pojoaque Pueblo and BuffaloThunder's conduct are not 'directly related to, andnecessary for, the licensing and regulation' of Class IIIgaming activities. 25 U.S.C. § 2710(d)(3)(C)(I. ... JudgeBiedscheid concluded correctly that, because Pena's accidentwas 'proximately caused by the conduct of the GamingEnterprise,' he has jurisdiction over Pena's State tortsuit."

In Mohegan Tribal Gaming Authority v. Factory MutualInsurance Company, 2022 WL 2303841 Not Reported (Sup. Ct. CT2022), a Connecticut Superior Court dismissed the Mohegan TribalGaming Authority's claims that its insurer, Factory MutualInsurance Company, breached its contract by denying claimsfor compensation for losses the Authority sustained as a result ofCOVID-19: "Because the Authority's complaint doesnot allege 'physical loss or damage' as required forcoverage under the 'Protection and Preservation of PropertyTime Element' coverage and its assertion that the placement ofthe Communicable Disease coverage in section 6, 'AdditionalCoverages,' compels the conclusion that the Policy definescommunicable disease as 'physical loss or damage' iserroneous, no coverage is provided by the Policy under the'Protection and Preservation of Property Time Element'coverage. Further, because the Authority has failed to sufficientlyallege that the cessation of its operations was due to the'actual not suspected presence" of COVID-19 at the Resort,FM's motion to strike is granted in its entirety."

The content of this article is intended to provide a generalguide to the subject matter. Specialist advice should be soughtabout your specific circumstances.

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Do Native Americans have sovereign immunity? ›

A central axiom of Indian law centers on Indian tribes' status “as domestic dependent sovereigns.” And like other sovereign governmental entities, tribes enjoy federal common-law sovereign immunity.

Can Native Americans be sued? ›

Put simply, the rule is that Indian Tribes cannot be sued in any court unless the federal congress has passed, and the president has signed, legislation waiving the tribe's immunity or the tribe itself has waived its immunity.

Does the Bill of Rights apply to Indian reservations? ›

The U.S. Bill of Rights does apply in Indian Country when the government, except for tribal government, violates rights protected by the Bill of Rights. No Indian tribe shall deny anyone within its jurisdiction the equal protection of its laws or deprive anyone of liberty or property without due process of law.

Can tribal members sue their own tribe? ›

Similar to other sovereign governments, Native American tribes enjoy common law sovereign immunity and cannot be sued.

Do U.S. marshals have jurisdiction on Indian reservations? ›

Answer and Explanation: Yes, generally lands within Indian reservations are subject to the jurisdiction of the federal government. Also, U.S. Marshall's have the same level of purview over state crimes that become federal felony crimes.

Does the federal government have jurisdiction on Indian reservations? ›

"We do not have to ask ourselves, 'If tribes have no criminal jurisdiction over non-Indians for acts committed on reservations, who does'? The answer is clear and unchanged: the federal government does."


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