National Farmers Union Insurance Co. v. Crow Tribe of Indians

471 U.S. 845, 105 S.Ct. 2447, 85 L.Ed.2d 818 (1985)

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National Farmers Union Insurance Co. v. Crow Tribe of Indians

United States Supreme Court
471 U.S. 845, 105 S.Ct. 2447, 85 L.Ed.2d 818 (1985)

  • Written by Lauren Groth, JD
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Facts

A state-run elementary school was located on the Crow Reservation on land owned by the State of Montana. Leroy Sage (defendant), a young Crow student, was struck and injured by a motorcycle on school property. Sage sued the school district (plaintiff) in the Crow Tribal Court (defendant) and obtained a default judgment for damages against the school district. The school district sued in federal court, seeking to enjoin execution of the tribal court’s judgment. The school district asserted that the district court had federal-question jurisdiction under 28 U.S.C. § 1331 to determine the extent of tribal authority over the non-Indian school district. Ultimately, the district court granted the school district a permanent injunction against the tribal judgment, holding that the Crow Tribal Court lacked jurisdiction over non-Indians in civil tort matters. The United States Court of Appeals for the Ninth Circuit reversed, holding that the district court did not have constitutional, statutory, or common-law jurisdiction to hear the case. The United States Supreme Court granted certiorari.

Rule of Law

Issue

Holding and Reasoning (Stevens, J.)

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