## Facts

- Jerry Teague, a non-Indian, served as general manager of the Bad River Band’s casino under 1993 and 1995 employment contracts.
- After Teague’s termination, he filed suit in Wisconsin circuit court seeking enforcement of the contracts and related relief.
- More than a year later, the Band filed a tribal-court action challenging the contracts’ validity under tribal law.
- The tribal court entered a default judgment for the Band, declaring the contracts null and void.
- The Wisconsin circuit court later entered a judgment awarding Teague damages for breach of the same contracts, creating conflicting state and tribal judgments.
- After remand following earlier litigation, the Band moved to reopen the Wisconsin judgment, arguing the circuit court must recognize the prior tribal judgment under Wis. Stat. § 806.245 and/or comity; the circuit court denied the motion.
- The court of appeals certified the matter to the Wisconsin Supreme Court to determine the effect of the tribal default judgment on the state judgment.

## Issues

1. Whether Wis. Stat. § 806.245 or comity required the circuit court to recognize and give effect to the tribal court’s prior default judgment invalidating the employment contracts.
2. Whether the circuit court erred by refusing to reopen and vacate the state judgment that conflicted with the earlier tribal judgment.
3. How Wisconsin courts should allocate authority between concurrent state and tribal proceedings to avoid inconsistent judgments when tribal sovereign interests and tribal law are directly implicated.

## Decision

- The Wisconsin Supreme Court reversed the circuit court’s order denying the Band’s motion to reopen.
- The court remanded with directions consistent with giving effect to the tribal court judgment, thereby resolving the conflict in favor of the prior tribal judgment.
- The court applied a multi-factor comity analysis, treating § 806.245 as a strong indicator of state policy favoring recognition of qualifying tribal judgments.
- The court concluded that the balance of comity considerations favored ceding to the tribal judgment, given its earlier entry, the centrality of tribal law and governance concerns, and the need to prevent races to judgment and inconsistent outcomes.

## Legal Principles

- Indian tribal courts are courts of an independent sovereign; state procedural doctrines such as “first-filed” or “prior action pending” do not automatically control concurrent tribal proceedings.
- Wisconsin courts must use comity principles to allocate authority between state and tribal forums when parallel proceedings risk inconsistent results.
- Wis. Stat. § 806.245 reflects a legislative policy of extending recognition akin to full faith and credit to tribal judgments when statutory prerequisites are satisfied; that policy weighs heavily in comity analysis.
- When a valid prior tribal judgment addresses disputes tied to tribal law and tribal self-government interests, Wisconsin courts generally should recognize the tribal judgment and avoid entering or maintaining a conflicting state judgment.
- Comity analysis may consider timing of judgments, subject matter and governance interests, fairness and procedural regularity of the tribal proceeding (including default), and reciprocity and other statutory recognition conditions.

## Conclusion

The Wisconsin Supreme Court held that the circuit court should have reopened the case and recognized the tribal court’s earlier default judgment invalidating the contracts; under comity informed by § 806.245, the prior tribal judgment displaced the later conflicting state judgment awarding Teague contract damages.


Teague v. Bad River Band of Lake Superior Tribe of Chippewa Indians, 665 N.W.2d 899 (Wis. 2003)