## Facts

- The Department of the Interior accepted the Bradley Property in Michigan into trust for the Match-E-Be-Nash-She-Wish Band of Pottawatomi Indians under 25 U.S.C. § 5108, and the Tribe opened a casino on the land.
- David Patchak, a nearby landowner, sued federal officials, alleging the Secretary lacked statutory authority to take the land into trust because the Tribe was not “under federal jurisdiction” in 1934.
- The Supreme Court previously allowed the suit to proceed under the Administrative Procedure Act’s waiver of sovereign immunity and found Patchak within the relevant zone of interests.
- While the case was pending on remand, Congress enacted the Gun Lake Trust Land Reaffirmation Act of 2014, reaffirming the Bradley Property as trust land.
- The Act also provided that any action “relating to” the Bradley Property “shall not be filed or maintained in a Federal court and shall be promptly dismissed.”
- Relying on the Act, the district court dismissed the case for lack of jurisdiction; the D.C. Circuit affirmed.

## Issues

1. Whether Congress violated Article III and separation-of-powers limits by requiring dismissal of pending federal litigation “relating to” a specific parcel of trust land.
2. Whether the statute permissibly changed the governing law by withdrawing jurisdiction or restoring sovereign immunity, rather than directing a result under prior law.

## Decision

- The Supreme Court affirmed, upholding the statute and requiring dismissal of Patchak’s suit.
- A plurality concluded the statute validly stripped federal-court jurisdiction over actions relating to the Bradley Property, including pending suits, and therefore did not dictate a rule of decision under existing law.
- Concurring Justices agreed with dismissal but read the statute primarily as restoring the United States’ sovereign immunity for suits relating to the Bradley Property, displacing the APA waiver.
- The dissent would have held the statute unconstitutional because it targeted a single pending case and compelled its dismissal, functioning as legislative adjudication barred by Article III.

## Legal Principles

- Congress may alter the jurisdiction of the lower federal courts and may apply such jurisdictional changes to pending cases, so long as it changes the law rather than compelling results under preexisting law.
- A statute that removes federal jurisdiction over a defined category of actions may be constitutional even if it effectively ends specific ongoing litigation.
- Congress may withdraw or narrow a prior waiver of federal sovereign immunity for a defined category of suits, thereby requiring dismissal of those actions.
- Article III limits are implicated when legislation is properly characterized as prescribing outcomes in identified cases without changing the applicable legal standards.

## Conclusion

The Court held that Congress could require dismissal of all federal suits relating to the Bradley Property because the statute operated as a permissible withdrawal of adjudicatory authority—either by stripping jurisdiction or by restoring sovereign immunity—rather than an unconstitutional command that courts resolve an existing case under old law.


Patchak v. Zinke, 138 S. Ct. 897 (2018)