Teague v. Bad River Band of Lake Superior Tribe of Chippewa Indians

665 N.W.2d. 899 (2003)

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Teague v. Bad River Band of Lake Superior Tribe of Chippewa Indians

Wisconsin Supreme Court
665 N.W.2d. 899 (2003)

Facts

Jerry Teague (plaintiff) was the general manager of a casino owned by the Bad River Band of Lake Superior Tribe of Chippewa Indians (the tribe) (defendant) on the tribe’s reservation. The tribe terminated Teague’s employment, and Teague filed suit in a Wisconsin circuit court, claiming the tribe had breached the employment contract. State court was the choice of forum in the employment contract. A year later, the tribe filed suit against Teague in tribal court, seeking a declaratory judgment to invalidate the employment contract. The state court and tribal court both had personal and subject-matter jurisdiction, and each was aware of the pending matter in the other court. While both matters were pending, the Wisconsin Supreme Court halted both proceedings and ordered the courts to confer and resolve which court should proceed according to principles of comity. The Wisconsin Supreme Court explained that the first-in-time action did not necessarily get priority and also that Wisconsin’s full-faith-and-credit statute was inapplicable. Ultimately, however, neither court was willing to forfeit jurisdiction over the matter. Therefore, both courts proceeded to judgment and reached opposite decisions. The tribal court found in the tribe’s favor, and the state court subsequently found in Teague’s favor. The matter went back to the Wisconsin Supreme Court for a second time when Teague and the tribe each requested that the court enforce the judgment in each of their respective favors.

Rule of Law

Issue

Holding and Reasoning (Abrahamson, C.J.)

Concurrence (Crooks, J.)

Dissent (Prosser, J.)

Dissent (Wilcox, J.)

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