Facts
- A Crow Indian minor was injured in a motorcycle accident in the parking lot of a school located within the Crow Reservation on land owned by the State of Montana.
- The minor, through a guardian, sued School District 17 (a Montana political subdivision) in Crow Tribal Court and obtained a default judgment.
- The school district and its insurer, National Farmers Union Insurance Companies, filed suit in federal district court under 28 U.S.C. § 1331 seeking to enjoin enforcement of the tribal-court judgment.
- Petitioners alleged that federal law divested the Crow Tribe of civil adjudicatory authority over a non-Indian defendant for a tort occurring on state-owned land within the reservation.
- The federal district court enjoined execution of the tribal judgment, concluding the tribal court lacked jurisdiction over a civil action against a non-Indian.
- The Ninth Circuit reversed, holding the district court lacked authority to review and enjoin the tribal judgment in that posture.
Issues
- Whether 28 U.S.C. § 1331 gives federal district courts jurisdiction over a claim that a tribal court exceeded the lawful limits of its civil jurisdiction over a non-Indian defendant.
- If § 1331 jurisdiction exists, whether the federal court may decide the tribal-jurisdiction question before the parties exhaust available remedies in the tribal court system.
Decision
- The Supreme Court unanimously reversed the Ninth Circuit and remanded.
- The Court held that § 1331 encompasses the federal question whether the tribal court exceeded the lawful limits of its jurisdiction; petitioners stated a claim “arising under” federal law.
- The Court held that, as a matter of comity, parties generally must exhaust tribal-court remedies before the federal court entertains the challenge to tribal-court jurisdiction.
- The Court did not decide the merits of the tribal court’s jurisdiction in this case, directing that the matter be addressed first in tribal court, with potential later federal review.
Legal Principles
- A federal court has federal-question jurisdiction under 28 U.S.C. § 1331 to hear a claim that a tribal court has exceeded the lawful bounds of its civil jurisdiction over a non-Indian.
- The “existence and extent” of tribal-court jurisdiction is a substantial question of federal law, including the extent to which tribal sovereignty has been altered or limited by federal law.
- As a prudential rule grounded in comity and federal policy supporting tribal self-government, a party challenging tribal-court jurisdiction must ordinarily exhaust tribal-court remedies before seeking federal judicial relief.
- Exhaustion is not a jurisdictional bar; the district court may dismiss the action or stay it pending completion of tribal proceedings.
- Exhaustion may be excused in limited circumstances (e.g., plainly absent jurisdiction, futility, or irreparable harm), but absent such circumstances the tribal court should address jurisdiction first.
Conclusion
The Court held that federal district courts may review, under § 1331, whether a tribal court has exceeded its civil jurisdiction over non-Indians, but required litigants to exhaust available tribal-court remedies before obtaining federal adjudication of that jurisdictional challenge.