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Iowa Mutual Insurance Co. v. LaPlante
United States Supreme Court
480 U.S. 9 (1987)
Edward LaPlante (defendant), a member of the Blackfeet Indian Tribe in Montana, was injured on the reservation while driving a cattle truck as an employee of Wellman Ranch (Wellman), a Montana corporation owned by members of the Blackfeet Tribe. LaPlante sued Wellman and Wellman’s insurer, Iowa Mutual Insurance Company (Iowa Mutual) (plaintiff) in tribal court. LaPlante sought damages from Wellman for injuries and compensatory and punitive damages from Iowa Mutual for bad faith refusal to settle LaPlante’s claim against Wellman. The tribal court claimed jurisdiction over Iowa Mutual as a non-Indian engaged in commercial relations with Indians on the reservation. Iowa Mutual sued in federal court based on diversity jurisdiction under 28 U.S.C. § 1332. Iowa Mutual sought a declaratory judgment that Iowa Mutual was not obligated to defend or indemnify Wellman under the terms of the insurance policy. Iowa Mutual contended that it was not required to exhaust tribal court remedies before proceeding to federal court on diversity-based claims. The district court dismissed the action, holding that Iowa Mutual was required to exhaust remedies in tribal court. The Ninth Circuit affirmed. The United States Supreme Court granted certiorari.
Rule of Law
Holding and Reasoning (Marshall, J.)
Concurrence/Dissent (Stevens, J.)
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