NFU Ins. Cos. v. Crow Tribe
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471 U.S. 845 (1985)
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U.S. Supreme Court
NFU Ins. Cos. v. Crow Tribe, 471 U.S. 845 (1985)
National Farmers Union Insurance Cos. v. Crow Tribe of Indians
Argued April 16, 1985
Decided June 3, 1985
471 U.S. 845
Respondent Crow Indian minor was struck by a motorcycle in the parking lot of a school located within the Crow Indian Reservation but on land owned by the State of Montana. Through his guardian, the minor brought a damages action in the Crow Tribal Court against petitioner School District, a political subdivision of the State, and obtained a default judgment. Thereafter, the School District and its insurer, also a petitioner, brought an action in Federal District Court for injunctive relief, invoking as a basis for federal jurisdiction 28 U.S.C. § 1331, which provides that a federal district court "shall have original jurisdiction of all civil actions arising under the Constitution, laws, or treaties of the United States." The District Court held that the Tribal Court had no jurisdiction over a civil action against a non-Indian, and accordingly entered an injunction against execution of the Tribal Court judgment. The Court of Appeals reversed, holding that the District Court had no jurisdiction to enter such an injunction.
1. Section 1331 encompasses the federal question whether the Tribal Court exceeded the lawful limits of its jurisdiction. Since petitioners contend that federal law has divested the Tribe of its power to compel a non-Indian property owner to submit to the civil jurisdiction of the Tribal Court, it is federal law on which petitioners rely as a basis for the asserted right of freedom from Tribal Court interference. They have, therefore, filed an action "arising under" federal law within the meaning of § 1331. Pp. 471 U. S. 850-853.
2. Exhaustion of Tribal Court remedies is required, however, before petitioners' claim may be entertained by the District Court. The existence and extent of the Tribal Court's jurisdiction requires a careful examination of tribal sovereignty and the extent to which that sovereignty has been altered, divested, or diminished, as well as a detailed study of relevant statutes, Executive Branch policy as embodied in treaties and elsewhere, and administrative or judicial decisions. Such an examination and study should be conducted in the first instance by the Tribal Court. Pp. 471 U. S. 853-857.
3. Until petitioners have exhausted the available remedies in the Tribal Court, it would be premature for the District Court to consider
any relief. Whether the federal action should be dismissed or merely held in abeyance pending the development of the Tribal Court proceedings is a question that should be addressed in the first instance by the District Court. P. 471 U. S. 857.
736 F.2d 1320, reversed and remanded.
STEVENS, J., delivered the opinion for a unanimous Court.