The United States District Court for the Eastern District of California has denied the State of California's motion to reconsider its prior ruling dismissing state law claims against tribal officials of the Alturas Indian Rancheria. The Court reaffirmed its decision that Tribal officials acting in their official capacities are protected by the doctrine of Tribal sovereign immunity.
California's motion for reconsideration relied on arguments that the Ex parte Young doctrine, traditionally allowing for prospective relief against state or Tribal officials for violations of federal law, should extend to state law claims. However, the court held that the State failed to show that the court committed clear error in its previous rejection of that argument, emphasizing that the Ex parte Young doctrine fundamentally relies on federal law supremacy, which is absent with the state law claims.
The court also noted that California did not present any new, binding precedents that would justify revisiting the earlier decision. This ruling highlights the continued protection of Tribal sovereignty by federal courts and the limited scope of legal doctrines that allow suits against Tribal officials under state law.
The firm's attorneys handling this matter are John M. Peebles, Conly J. Schulte, Tim Hennessy, and Gregory M. Narvaez. The case is State of California v. Phillip Del Rosa, et al., No. 2:23-cv-00743-KJM-SCR (E.D. Cal. Nov. 15, 2024).
For further information on how this case may impact other Indian tribes, contact Peebles Bergin Schulte & Robinson LLP.