Inyo County, California v. Paiute-Shoshone Indians of the Bishop Community of the Bishop Colony
The Court ruled that the Bishop Paiute Tribe could not sue a California county under the main federal civil-rights law to block a search of its casino's payroll records, because that law lets a sovereign like a tribe sue as a defendant's victim but does not let it invoke its own sovereign immunity as the basis for a lawsuit.
The case was sent back to the lower courts to figure out whether some other federal law might still let the Tribe pursue its claim that it is immune from the county's search warrant.
“Section 1983 was designed to secure private rights against government encroachment, see Will, 491 U. S., at 66, not to advance a sovereign's prerogative to withhold evidence relevant to a criminal investigation.”
Explaining why the tribe could not use the civil-rights law to assert sovereign immunity.
How it got here: A federal trial court dismissed the tribe's suit; the Ninth Circuit reversed in the tribe's favor; the county asked the Supreme Court to review that reversal.
The Case in Depth
What happened
A California county investigating welfare fraud asked a tribal casino for the employment records of several employees. The tribe, citing its own privacy policy, refused full cooperation, so county officials obtained a warrant and cut the locks on a storage facility to seize payroll records. The tribe and its casino corporation sued the county, the district attorney, and the sheriff, arguing the search violated the tribe's sovereign immunity and constitutional rights.
The question before the Court
Could a Native American tribe use a federal civil-rights law to stop a county from searching its casino's employee records?
Why it matters
Tribes across the country that want to resist state searches or subpoenas on reservation land cannot automatically rely on this civil-rights statute to do so in federal court. Counties and states investigating crimes connected to tribal businesses, like casinos, retain a path to enforce search warrants unless a tribe can find some other federal legal hook for its immunity claim.
What changes now
The case returns to the lower courts, which must now decide whether some source of federal law other than the civil-rights statute -- such as the general body of federal law governing tribes -- gives the tribe a legal basis to sue over its claimed immunity from the county's search. This is a final ruling on the civil-rights-statute question but leaves the broader jurisdictional dispute unresolved for now.
What this does not decide
The Court did not decide whether tribes can ever sue under this civil-rights statute in other situations, nor whether some other federal law lets this tribe pursue its sovereign-immunity claim. It also did not rule on whether the search itself was otherwise lawful.
Concurrences and dissents
How the Justices voted
Majority (8). Justice Ginsburg (author), joined by Justice Rehnquist, Justice O'Connor, Justice Scalia, Justice Kennedy, Justice Souter, Justice Thomas, and Justice Breyer.
Separate writings (1). Justice Stevens (author of a concurrence).
Concurrence — Justice Stevens
Justice Stevens agreed the case should be sent back but on different reasoning. He argued that tribes generally should count as 'persons' who can sue under the civil-rights statute when their own constitutional rights are violated, calling it demeaning to deny tribes the same access to that remedy as anyone else. He concluded the tribe still loses here because its claim relied entirely on judge-made tribal immunity doctrine rather than a right protected by the Constitution or a federal statute. Read the full concurrence →
How the Court got there
The legal reasoning, step by step
- The Court examined whether the tribe counted as a 'person' entitled to sue under the federal civil-rights statute, noting that courts decide who counts as a 'person' under a law by looking at the surrounding legal context, not just the dictionary meaning of the word.
- The Court had already assumed, as the parties agreed, that tribes -- like states -- cannot be sued under this civil-rights statute, following the Court's earlier ruling in Will v. Michigan Dept. of State Police that treated states the same way.
- Because the tribe was not challenging whether the warrant was properly issued or supported by probable cause, its claim rested entirely on its assertion of sovereign immunity, a government-type privilege rather than a personal right.
- The Court reasoned that the civil-rights statute exists to protect individuals from government overreach, not to give a sovereign government body a shield against otherwise valid law enforcement action.
- Applying that reasoning, the Court concluded that the tribe could not use this statute to assert its sovereign immunity, even though an individual tribal member with a personal constitutional claim could still sue under it.
- Because no other basis for federal court jurisdiction had been clearly addressed below, the Court left open whether a separate body of law covering Indian affairs might still support the tribe's claim to be free from the county's search.
Doctrinal impact
Cases affected by this decision
Reaffirms Will v. Michigan Dept. of State Police (491 U. S. 58)
Reaffirms that states are not 'persons' who can be sued under the civil-rights statute, extending the logic to tribes.