Justia U.S. 9th Circuit Court of Appeals Opinion Summaries

This case arose when the Colorado River Indian Tribes ("CRIT") exercised jurisdiction over appellants, a non-Indian closely held corporation and its non-Indian owner, in an unlawful detainer action for breach of a lease of tribal lands and trespass. The tribal court entered judgment in favor of the tribe and appellants appealed. At issue was the extent of the CRIT's civil authority over appellants who were acting on tribal land within the reservation. The court held that under the circumstances presented, where there were no sufficient competing state interests at play, the tribe had regulatory jurisdiction through its inherent authority to exclude, independent from the power recognized in Montana v. United States. The court also held that adjudicative jurisdiction also existed in light of Supreme Court precedent recognizing tribes' inherent civil authority over non-Indian conduct on tribal land and congressional interest in promoting tribal self-government. The court further held that in this instance, by applying traditional personal jurisdiction principles, the tribal court had personal jurisdiction over a non-Indian agent acting on tribal land. Accordingly, the court affirmed the district court's judgment as to the non-Indian corporation and reversed with respect to the non-Indian owner.

Plaintiff sued defendant seeking a declaratory judgment to the effect that defendant's liens were not valid, in whole or in part, where plaintiff received a substantial settlement from her insurer when she suffered serious injuries in a car accident and received extensive health care services from defendant. At issue was whether the district court properly granted summary judgment to defendant because it had a right to recover the money spent on plaintiff's medical care under 25 U.S.C. 1621e. The court reversed and held that section 1621e, which allowed healthcare providers to recover expenses from third-party tortfeasors, relevant insureres, or other third parties, did not apply to the action where defendant sought to enforce a right of recovery against plaintiff to whom it provided services.