The question in this case is whether New York courts have jurisdiction to resolve a dispute between competing factions of the Cayuga Nation as to possession of certain tribal property.
In general, federal and state courts lack authority to resolve internal disputes about tribal law or governance. But the Secretary of the Bureau of Indian Affairs (BIA) within the U.S. Department of the Interior has authority to manage all “Indian” affairs and all matters arising out of “Indian” relations, including the authority to make recognition decisions regarding tribal leadership if the situation has deteriorated to the point that recognition of some government is essential for Federal purposes.
In 2016, the BIA resolved the competing claims of plaintiffs and defendants to leadership of the Cayuga Nation by recognizing plaintiffs as the Nation’s lawful governing body. Plaintiffs then instituted this action asserting various causes of action all seeking to recover tribal property that had been allegedly wrongly occupied by the defendants. Defendants moved to dismiss the action for lack of subject matter, arguing that resolving the action would require a court impermissibly to resolve the dispute about tribal governance.
Supreme Court denied defendants’ motion, and a divided Third Department affirmed. The majority held that there was no need to resolve the tribal dispute because the BIA had already done so; the court would simply defer to the BIA’s decision. In the dissenters’ view, resolution of plaintiffs’ claims would require determining the tribal leadership dispute and that the BIA had not already resolved that dispute.
The Fourth Department granted leave to appeal.
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