## Facts

- The Sycuan, Barona, and Viejas Bands of Mission Indians operated gaming centers on their reservations in San Diego County, California.
- San Diego County officials obtained state-court search warrants and executed searches at the tribes’ gaming facilities, seizing gaming machines (including Sycuan’s video pull-tab devices), cash, and records.
- The San Diego County District Attorney commenced state criminal prosecutions against four individuals employed at the tribes’ gaming centers, based on allegations that the gaming being offered violated California law and IGRA.
- The tribes filed suit in federal district court seeking declaratory and injunctive relief against the Sheriff and District Attorney, arguing that IGRA and federal Indian-law limits on Public Law 280 jurisdiction barred the state’s raids and prosecutions.
- The district court granted declaratory and injunctive relief, including an injunction barring the pending state prosecutions.
- The district court separately denied Sycuan’s request for return of the seized video pull-tab machines, concluding they were Class III gaming devices (slot-machine-like) that could be operated only under a Tribal–State compact, which did not exist. Under a stipulation, the Sheriff was directed to return the devices to their non-tribal owner/lessor.
- The District Attorney appealed the injunction and related relief. Sycuan cross-appealed the Class III classification of its video pull-tab machines.

## Issues

1. Whether the tribes could use 42 U.S.C. § 1983 to obtain declaratory and injunctive relief against county officials conducting state criminal enforcement against on-reservation gaming.
2. Whether the Anti-Injunction Act, 28 U.S.C. § 2283, barred the federal court from enjoining the ongoing state criminal prosecutions.
3. Whether Younger abstention required the federal court to refrain from enjoining the pending state prosecutions of tribal gaming employees.
4. Whether California had criminal enforcement jurisdiction under Public Law 280 (18 U.S.C. § 1162) and state gambling laws to raid the tribal gaming facilities and prosecute the employees, given IGRA’s regulatory scheme.
5. Whether Sycuan’s video pull-tab machines were Class III gaming under IGRA, requiring a Tribal–State compact.

## Decision

- The Ninth Circuit affirmed the district court’s judgment in all respects.
- The court held that § 1983 was available as a vehicle for prospective equitable relief against state officials alleged to be acting under color of state law in violation of federally protected rights arising under IGRA and federal Indian law.
- The court held the federal injunction was not barred by the Anti-Injunction Act because the relief fit within a recognized statutory exception applicable to § 1983-based claims.
- The court held Younger abstention did not require dismissal or a stay because the federal action was brought by tribal governments to protect federally defined limits on state authority in Indian gaming, and the requested relief prevented state proceedings asserted to be beyond the state’s lawful jurisdiction.
- On the merits of jurisdiction, the court agreed that IGRA’s allocation of authority over Indian gaming, together with limits on state power in Indian country even in a Public Law 280 state, meant the county officials lacked authority to conduct the challenged enforcement actions against the tribes’ gaming operations through the state prosecutions at issue.
- On cross-appeal, the court affirmed that Sycuan’s video pull-tab machines were Class III gaming devices; without a Tribal–State compact, operating them violated IGRA, and Sycuan was not entitled to have the machines returned for use.

## Legal Principles

- Tribes may seek prospective declaratory and injunctive relief under 42 U.S.C. § 1983 against state or local officials who, acting under color of state law, allegedly interfere with federal rights governing tribal gaming and on-reservation governance.
- The Anti-Injunction Act does not bar a federal injunction against state proceedings when the injunction falls within an applicable statutory exception, including relief authorized in § 1983 actions to protect federal rights.
- Younger abstention is not required when tribal sovereigns bring federal actions to restrain state criminal proceedings that conflict with federal law allocating jurisdiction and regulatory authority in Indian country.
- In a Public Law 280 state, state enforcement authority in Indian country turns on whether the state law is criminal/prohibitory rather than civil/regulatory; IGRA further structures and limits state involvement in Indian gaming, channeling it primarily through the Tribal–State compact process for Class III gaming.
- Under IGRA, Class III gaming (including slot-machine-like electronic devices) may be conducted on Indian lands only if the statutory conditions are met, including operation under a valid Tribal–State compact.

## Conclusion

Sycuan Band of Mission Indians v. Roache held that federal courts could enjoin San Diego County’s on-reservation gambling prosecutions because, in light of IGRA and federal limits on state jurisdiction in Indian country, the state’s enforcement effort conflicted with the federal allocation of authority over tribal gaming; at the same time, the Ninth Circuit agreed that Sycuan’s video pull-tab machines were Class III devices that could not be lawfully operated without a Tribal–State compact.


Sycuan Band of Mission Indians v. Roache, 54 F.3d 535 (1994)