Stillaguamish Tribe of Indians v. Washington, No. 17-35722 (9th Cir. 2019)
Annotate this CaseThe Ninth Circuit did not reach the merits of the Tribe's sovereign immunity defense and held, on de novo review, that the district court lacked subject matter jurisdiction in an action brought by the Tribe against the state, seeking a declaration that the Tribe's sovereign immunity barred any lawsuit arising from a particular contract with Washington. The panel held that the Tribe's anticipatory defense to a state court lawsuit did not form a basis for federal jurisdiction. Therefore, the panel vacated the district court's judgment and remanded with instructions to dismiss for lack of subject matter jurisdiction.
Court Description: Subject Matter Jurisdiction. The panel vacated the district court’s summary judgment in favor of an Indian tribe that sought a declaration that its sovereign immunity barred any lawsuit arising from a particular contract with the State of Washington. The panel held that the district court lacked subject matter jurisdiction because the tribe’s anticipatory defense to a state court lawsuit did not amount to a cause of action based on federal law and thus did not form a basis for federal question jurisdiction. The panel vacated the district court’s judgment and remanded with instructions to dismiss for lack of subject matter jurisdiction.
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