Justia Contracts Opinion Summaries

Defendant Linus Poitra appealed a default judgment entered by the district court regarding a lease between Plaintiff Darrel Gustafson as lessee and Leon and Linus Poitra as lessors. Linus Poitra argued the district court did not have subject matter jurisdiction to enter the default judgment because the Poitras were members of the Turtle Mountain Band of Chippewa Indians, and the land subject to the lease is Indian-owned fee land located within the boundaries of the Turtle Mountain Indian Reservation. Linus Poitra argued the default judgment infringed upon tribal sovereignty because of cases pending in the Turtle Mountain Tribal Court. Upon review of the applicable legal authority and the evidence presented at trial, the Supreme Court vacated the default judgment finding that the district court did not have subject matter jurisdiction over the lease.

Plaintiff appealed the dismissal for lack of subject matter jurisdiction of its action against defendant, alleging tort, contract, and state statutory claims and seeking, among other remedies, a constructive trust and declaratory judgment over an oil and gas lease located on allotted land, wherein title to the land was held by the United States in trust for various Indian allottees. At issue was whether the district court had federal jurisdiction. The court held that 28 U.S.C. 1360(b), 28 U.S.C. 1331, and 25 U.S.C. 345 did not grant federal jurisdiction and therefore, plaintiff presented no basis for concluding that the action was within the "limited jurisdiction" of federal courts. Accordingly, the district court properly dismissed the suit based on lack of subject matter jurisdiction and the court did not need to reach any other issues raised by the parties, including exhaustion of tribal remedies. The court noted, however, that its holding did not preclude plaintiff from seeking relief in Blackfeet Tribal Court.

Twenty three former tribal employees sued the Seneca-Cayuga Tribe of Oklahoma for breach of employment contracts. The contracts contained a limited waiver of sovereign immunity. Tribal law requires that waiver of sovereign immunity must be consented to by the Business Committee of the Tribe by resolution. The trial judge, on motion for reconsideration, granted the Tribe's motion to dismiss for lack of subject matter jurisdiction and dismissed the case. On appeal, the question before the Supreme Court was whether the Tribe expressly and unequivocally waived its sovereign immunity with respect to Plaintiffs' employment contracts. Upon review of the contracts and the applicable tribal resolutions and legal standards, the Supreme Court held that waiver of sovereign immunity was neither expressed nor consented to in the Business Committee's resolutions that authorized the Chief to sign the employment contracts. The Court affirmed the lower courtâs decision.

This case stems from Plaintiff Crowe & Dunlevy, P.C.'s (Crowe) legal representation of the Thlopthlocco in the Muscogee (Creek) Nation District Court in 2007. Nathan Anderson, a member of the Thlopthlocco Nation attempted a coup d'etat by declaring himself the only valid leader and purported to appoint a new government. While the "coup" proceeded through the tribal courts, the matter of paying the legal bill for Crowe's representation came up. With the "official" government in dispute, and tribal business halted from an injunction issued until the case was resolved, Mr. Anderson argued that his legal fees should be paid from the tribal treasury. The tribal district court dismissed his claim, reasoning that until the litigation was resolved, no one knew who had authority to spend Thlopthlocco funds. The court then ordered that any attorney fees paid from the tribe's treasury be refunded. Instead of complying with the order, Crowe filed suit with the federal district court, seeking to enjoin the tribal court from ordering a return of the legal fees. The federal court ruled in favor of Crowe, and the tribal judge, Defendant Judge Gregory Stidam, appealed. On appeal to the Tenth Circuit, Judge Stidham argued the case should have been dismissed because he was entitled to sovereign and judicial immunity. The Tenth Circuit found that the lower court did not abuse its discretion in granting the injunction against Judge Stidham's order. The Court affirmed the lower court's decision.

Hollywood Mobile Estates Limited ("Hollywood") filed a complaint in district court against the Seminole Tribe of Florida ("Tribe") where the Tribe and the Secretary of the Interior ("Secretary") approved a lease assignment between Hollywood and the Tribe. At issue was whether Hollywood alleged an injury fairly traceable to the Secretary or redressable by the district court in a complaint that alleged that the Tribe had threatened to repossess tribal property in violation of the lease. Also at issue was whether the interests of Hollywood were within the zone of interests protected by the Indian Long-Term Leasing Act, 25 U.S.C. 415, and its accompanying regulations. The court held that Hollywood lacked constitutional standing to maintain its complaint and therefore, vacated in part the judgment entered by the district court and remanded with instructions to dismiss for lack of subject matter jurisdiction. The court also held that Hollywood lacked prudential standing to sue the Secretary and therefore, affirmed the denial of the motion for leave to amend the complaint as futile.