Narrative Opinion Summary
This case involves cross motions for summary judgment regarding the acquisition of land in trust for the lone Band of Miwok Indians, permitting gaming operations. The County of Amador challenged the Department of the Interior's decision under the Indian Reorganization Act (IRA) and the Indian Gaming Regulatory Act (IGRA). The plaintiff argued the decision was arbitrary and capricious, and contested the recognition of the lone Band as a federally recognized tribe. The court evaluated the historical federal jurisdiction over the Band as of 1934, relying on actions from the 1970s and subsequent determinations. The court also reviewed procedural timelines under the Administrative Procedures Act (APA) and addressed the statute of limitations under 28 U.S.C. § 2401. The defendants contended that the 'restored lands' exception under IGRA applied to the Plymouth Parcels. The court ultimately granted summary judgment in favor of the defendants, concluding that the Department's actions were neither arbitrary nor capricious, and the plaintiff's challenges were not barred by the statute of limitations. The decision affirms the Department's authority to take the land into trust for gaming purposes, recognizing the lone Band's federal status and jurisdictional continuity under the IRA.
Legal Issues Addressed
Administrative Procedures Act (APA) Review Standardssubscribe to see similar legal issues
Application: Under the APA, the court's review focused on whether the agency's decision was arbitrary, capricious, or not in accordance with the law based on the administrative record.
Reasoning: In APA cases, the court's role is limited to determining whether the agency's decision is supported by the administrative record and adheres to legal standards, not to resolve factual disputes.
Indian Gaming Regulatory Act (IGRA) and Restored Lands Exceptionsubscribe to see similar legal issues
Application: The court assessed whether the Plymouth Parcels qualified as restored lands under IGRA, allowing gaming operations by the lone Band.
Reasoning: The Department invokes the 'restored lands' exception under section 2719(b)(1)(B)(iii). The Bureau of Indian Affairs (BIA) implemented regulations for this section in May 2008, effective August 2008, with specific criteria outlined in sections 292.7 and 292.10.
Indian Reorganization Act (IRA) and Federal Jurisdictionsubscribe to see similar legal issues
Application: The court considered the historical actions of the federal government regarding the lone Band to determine if they were under federal jurisdiction as of 1934, as required by the IRA.
Reasoning: The Secretary’s justification for the Band's jurisdictional status remaining intact in 1934 relies on actions from the 1970s by California Indian Legal Services, a 1972 determination, a 2006 Internal Land Determination (ILD), and a 2011 U.S. District Court recognition of the Band's ongoing governmental relationship with the United States.
Statute of Limitations under 28 U.S.C. § 2401subscribe to see similar legal issues
Application: The court analyzed whether the plaintiff's challenge was time-barred by the statute of limitations for actions against the United States.
Reasoning: The parties are debating whether the six-year statute of limitations in 28 U.S.C. § 2401 prevents the Plaintiff from contesting determinations made by the Department referenced in the Record of Decision (ROD).