Blatchford v. Native Village of Noatak
Headline: Court limits tribes’ ability to sue states by ruling that state immunity blocks tribal damage suits in federal court and that a 1966 federal law did not remove that immunity, affecting tribal money claims against States.
Holding:
- Prevents tribes from obtaining money damages from States in federal court under §1362.
- Leaves tribes able to seek injunctions against state officials, subject to lower-court review.
- Requires clear congressional authorization or State consent for tribal money suits against States.
Summary
Background
A state official in Alaska changed a revenue-sharing program that had given annual payments to Native village governments after the State’s attorney general said the original program might violate the State Constitution. Native village governments (Indian tribes) sued in 1985, asking a federal court to require the State to pay the money they said they were owed and asserting federal equal-protection claims. The District Court dismissed the suit based on the Eleventh Amendment (state sovereign immunity), the Ninth Circuit reversed, and the State appealed to the Supreme Court.
Reasoning
The Court addressed two basic questions in plain terms: whether the Constitution’s protections for state immunity stop tribal lawsuits for money damages in federal court, and whether a 1966 federal statute giving tribes access to federal courts (28 U.S.C. §1362) removed that immunity. The majority relied on past decisions saying state immunity protects States from suits unless consent appears clearly. It concluded that historical sources and precedent do not show the States waived immunity in favor of tribes, and that the 1966 law was not an unmistakably clear statement abolishing that immunity. Thus the Court held the Eleventh Amendment bars the tribes’ damage claims and that §1362 did not abrogate that protection.
Real world impact
As a result, tribes cannot pursue money-damage suits against a State in federal court under §1362 unless Congress clearly authorizes such suits or the State consents. The Court left for the lower courts to decide whether tribes can still seek injunctive relief against state officials. This decision narrows tribal access to federal money remedies against States and requires clearer congressional action to change that rule.
Dissents or concurrances
The dissent argued the Eleventh Amendment should not bar such tribal suits, that §1362 was meant to let tribes litigate like the United States trustee, and that the clear-statement rule should not block tribal claims; the dissent would have affirmed the Ninth Circuit.
Opinions in this case:
Ask about this case
Ask questions about the entire case, including all opinions (majority, concurrences, dissents).
What was the Court's main decision and reasoning?
How did the dissenting opinions differ from the majority?
What are the practical implications of this ruling?