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Keywords

lawsuitinjunctiontrustsovereign immunity

precedent

Related Cases

Michigan v. Bay Mills Indian Community, 572 U.S. 782, 134 S.Ct. 2024, 188 L.Ed.2d 1071, 82 USLW 4398, 14 Cal. Daily Op. Serv. 5665, 2014 Daily Journal D.A.R. 6503, 24 Fla. L. Weekly Fed. S 765

Facts

The State of Michigan entered into a compact with the Bay Mills Indian Community under the Indian Gaming Regulatory Act, allowing the Tribe to conduct class III gaming on Indian lands but prohibiting it from doing so outside that territory. Bay Mills opened a second casino on land purchased with earnings from a congressionally established land trust, claiming it qualified as Indian land. Michigan disagreed and filed a lawsuit to enjoin the casino's operation, leading to a preliminary injunction that was later vacated by the Sixth Circuit, which ruled that tribal sovereign immunity barred the suit.

In 2010, Bay Mills opened another class III gaming facility in Vanderbilt, a small village in Michigan's Lower Peninsula about 125 miles from the Tribe's reservation.

Issue

Does tribal sovereign immunity bar the State of Michigan's suit against the Bay Mills Indian Community for operating a casino outside Indian lands?

We hold that immunity protects Bay Mills from this legal action.

Rule

Indian tribes possess inherent sovereign immunity from suit unless Congress has unequivocally abrogated that immunity. The Indian Gaming Regulatory Act allows states to sue tribes to enjoin gaming activities only when those activities occur on Indian lands.

Unless and until Congress acts, the tribes retain their historic sovereign authority.

Analysis

The Supreme Court applied the rule of tribal sovereign immunity, determining that the IGRA's provision allowing states to sue tribes only applies to gaming activities located on Indian lands. Since Michigan's suit was based on the premise that the casino was outside Indian lands, the Court concluded that the suit was barred by tribal sovereign immunity. The Court also rejected Michigan's arguments for a broader interpretation of IGRA that would allow for suits regarding off-reservation gaming.

The upshot is this: Unless Congress has authorized Michigan's suit, our precedents demand that it be dismissed.

Conclusion

The Supreme Court affirmed the Sixth Circuit's ruling, holding that Michigan's suit against Bay Mills is barred by tribal sovereign immunity. The Court emphasized that unless Congress explicitly states otherwise, tribal immunity remains intact even for commercial activities conducted off-reservation.

Because IGRA's plain terms do not abrogate Bay Mills' immunity from this suit, Michigan (and the dissent) must make a more dramatic argument.

Who won?

Bay Mills Indian Community prevailed in the case because the Supreme Court upheld the principle of tribal sovereign immunity, concluding that Michigan's lawsuit was not authorized under the Indian Gaming Regulatory Act.

Michigan must therefore resort to other mechanisms, including legal actions against the responsible individuals, to resolve this dispute.

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