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Kiowa Tribe of Oklahoma v. Manufacturing Technologies, Inc.

United States Supreme Court
523 U.S. 751, 118 S.Ct. 1700, 140 L.Ed.2d 981 (1998)


Facts

The Kiowa Tribe of Oklahoma (tribe) (plaintiff) is a federally recognized Indian tribe. In 1990, a tribal entity, the Kiowa Industrial Development Commission, agreed to buy stock from Manufacturing Technologies, Inc. (defendant). The chairman of the tribe’s business committee signed a promissory note on behalf of the tribe. The parties disputed whether the note was signed on the Kiowa reservation or on nontribal land. The note did not designate a governing law. The note contained a provision stating: “Nothing in this Note subjects or limits the sovereign rights of the Kiowa Tribe of Oklahoma.” After the tribe defaulted on the note, Manufacturing Technologies sued the tribe in Oklahoma state court. The tribe moved to dismiss for lack of jurisdiction, contending that it had sovereign immunity. The trial court denied the motion and ruled for Manufacturing Technologies. The Oklahoma Court of Civil Appeals affirmed, and the Oklahoma Supreme Court declined review. The United States Supreme Court granted certiorari.

Rule of Law

Issue

Holding and Reasoning (Kennedy, J.)

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