Jamul Action Committee v. Simermeyer, No. 17-16655 (9th Cir. 2020)Annotate this Case
The Ninth Circuit affirmed the district court's dismissal for failure to join a required party in an action challenging the Jamul Indian Village's efforts to build a casino. The panel held that the distinction JAC urges between historic tribes and other tribal entities organized under the Indian Reorganization Act is without basis in federal law. The panel held that Jamul Indian Village is a federally recognized Indian tribe with the same privileges and immunities, including tribal sovereign immunity, that other federally recognized Indian tribes possess. Therefore, the Village's tribal sovereign immunity extends to its officers in this case. Because the Village is protected by tribal sovereign immunity, the panel agreed with the district court that the Village cannot be joined in this action and that the action cannot proceed in equity and good conscience without it.