Patchak v. Zinke
Headline: Congress’s narrow law barring lawsuits about a specific tribal land is upheld, letting the government and tribe block court challenges and effectively end the neighbor’s lawsuit threatening a casino.
Holding: This field is not used in the required schema and is intentionally left out.
- Ends the neighbor’s federal lawsuit challenging the tribe’s trust land.
- Lets the tribe and federal government block federal-court challenges about that land.
- Affirms Congress can change laws or limit federal jurisdiction for pending cases.
Summary
Background
A nearby landowner, David Patchak, sued the Secretary of the Interior after the Secretary took a 147-acre parcel (the Bradley Property) into trust for the Match‑E‑Be‑Nash‑She‑Wish Band of Pottawatomi Indians, which later opened a casino. This Court’s earlier decision (Patchak I) held that the Government’s immunity had been waived and that Patchak could proceed, and the case returned to district court. While the suit was pending, Congress enacted the Gun Lake Act, which ratified the trust status (§2(a)) and added §2(b) stating that any federal action “relating to” the Bradley Property shall not be maintained and must be promptly dismissed. The district court dismissed the suit and the D.C. Circuit affirmed.
Reasoning
The Court addressed whether §2(b) violated Article III by improperly usurping judicial power. The majority (opinion by Justice Thomas, joined by Justices Breyer, Alito, and Kagan) concluded §2(b) “changes the law” by stripping federal courts of jurisdiction over actions relating to the land, using jurisdictional language and applying “notwithstanding any other provision of law.” The majority rejected arguments that the statute merely ordered dismissal under old law (Klein) or unlawfully interfered with the Court’s earlier remand (Plaut). Justice Breyer concurred on contextual grounds. Justices Ginsburg and Sotomayor would decide the case by recognizing that Congress restored the Government’s sovereign immunity. Chief Justice Roberts dissented, arguing the Act targeted and decided a single pending case.
Real world impact
The ruling ends Patchak’s federal challenge and leaves the Bradley Property’s trust status and the Band’s casino protected from federal-court suits relating to that land. It affirms Congress’ broad power to change law or limit federal jurisdiction in specific circumstances and highlights differing views about whether such moves operate by stripping jurisdiction or restoring sovereign immunity. The decision narrows federal review of similar land-related suits as described in the opinion.
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