Document Type


First Page

E. Supp. 47


On June 10, 2011, in Water Wheel Camp Recreational Area, Inc. v. LaRance, the U.S. Court of Appeals for the Ninth Circuit held that a tribal court had jurisdiction over a non-Indian corporation and its non-Indian president through the tribe’s inherent authority to exclude and manage its land. The Ninth Circuit limited the application of Montana v. United States, a case restricting tribal authority, to situations involving non-tribal land or to situations in which competing state interests are at play. In so doing, the court gave tribal courts the breadth of power Congress intended.