Seminole Tribe v. Butterworth

Last updated
Seminole Tribe of Florida v. Butterworth
Seal of the United States Court of Appeals for the Fifth Circuit.svg
Court United States Court of Appeals for the Fifth Circuit
Full case nameSEMINOLE TRIBE OF FLORIDA, an Organized Tribe of Indians, as recognized under and by the Laws of the United States, Plaintiff-Appellee, v. Robert BUTTERWORTH, the duly elected Sheriff of Broward County, Florida, Defendant-Appellant.
DecidedOctober 5 1981
Citation(s)658 F.2d 310
Case history
Prior historyAff'g 491 F. Supp.1015 (S.D. Fla. 1980).
Subsequent historyCert. denied, 455 U.S. 1020 (1982).
Holding
The State of Florida does not have authority to enforce the Florida Bingo Statute on the Seminole Tribe of Florida's reservation, even though Florida is a Public Law 280 state, because the Bingo Statute is regulatory rather than prohibitory in nature.
Court membership
Judge(s) sitting Lewis R. Morgan, Paul Hitch Roney, and Phyllis A. Kravitch
Case opinions
MajorityLewis R. Morgan, joined by Phyllis A. Kravitch
Dissent Paul Hitch Roney

Seminole Tribe of Florida v. Butterworth, 658 F.2d 310 (5th Cir. 1981), was a United States Court of Appeals for the Fifth Circuit case that significantly influenced the development of modern Indian Gaming law. In Seminole Tribe, the Fifth Circuit ruled that the State of Florida did not have authority to enforce the Florida Bingo Statute on the Seminole Tribe of Florida's reservation, even though Florida is a Public Law 280 state with special rights to extend criminal and limited civil jurisdiction over Indian Country. Because of the decision, the Seminole Tribe was able to build and operate the nation's first tribally-owned high-stakes bingo parlor on their reservation in Florida, even though bingo for profit was illegal under Florida law at the time. Many other tribes later followed the Seminole Tribe's lead by building their own bingo parlors on their reservations, leading many scholars to call the Seminole Tribe's victory in this case the "birth" of modern commercial gambling on reservations. [1] [2]

Contents

Case

Facts

In the 1970s, the Seminole Tribe contracted with a private limited partnership that agreed to build and operate a large, high-stakes bingo hall on the Tribe's reservation in exchange for a percentage of profits as management fees. [3] The hall cost approximately $900,000 to construct, [4] it was one of the nation's first high-stakes bingo parlors, [5] and it was the very first tribally-owned high-stakes bingo parlor. [6] The Tribe made this investment in the bingo hall despite the fact that the hall's planned operation would be "clearly in violation" of the Florida Bingo Statute at that time, Fla. Stat. § 849.093(repealed in 1992 [7] ). The Bingo Statute only permitted certain charitable, religious, community, or other similar organizations to run bingo games, and even those organizations were limited to running games on less than two days per week with only one jackpot of less than $100 given out per day. [4] The Tribe's bingo hall operated six days per week and handed out multiple jackpots a day of much higher than $100 value. [8]

By 1979, construction on the bingo hall was completed. Shortly before the scheduled opening of the bingo hall, however, Robert Butterworth, the sheriff of Broward County, Florida, informed the Tribe he would make arrests for any violations of the Florida Bingo Statute on the reservation. [9] In response, the Seminole Tribe filed a lawsuit in the United States District Court for the Southern District of Florida, seeking a declaratory judgment and injunctive relief against Sheriff Butterworth. [10]

Issue and Arguments

The main issue in the case was whether the State of Florida, as a Public Law 280 state with special rights to exercise limited civil jurisdiction in Indian Country, had the authority to enforce the Florida Bingo Statute on the Seminole Tribe's reservation.

The Sheriff and the State of Florida, which participated in the lawsuit as amicus curiae, argued that the State of Florida had jurisdiction to enforce the Florida Bingo Statute on the Seminole Tribe's reservation. [11] Normally, a state lacks jurisdiction over activity on Indian reservations unless the federal government explicitly grants the state that authority. [12] However, a federal law called Public Law 280 granted certain states – including Florida – the right to exercise criminal and limited civil jurisdiction over Indian Country. [13] Thus, Florida argued that because it is a Public Law 280 state, it possesses the authority to enforce the Florida Bingo Statute on the Seminole Tribe's reservation. [11]

Meanwhile, the Seminole Tribe argued that the Sheriff and the State of Florida did not have the power to enforce the Florida Bingo Statute on the reservation. The Tribe argued that the Supreme Court case Bryan v. Itasca County indicates that, although Public Law 280 states have limited civil jurisdiction in Indian Country, they do not have "general regulatory powers." [14] Because the Florida Bingo Statute simply set limits on when, where, and how bingo games could be run and played rather than outright prohibiting bingo games, the Tribe argued that the Statute was regulatory rather than prohibitory in nature, meaning the Sheriff could not enforce it on the Tribe's reservation under Bryan. [15]

District Court Opinion

The District Court for the Southern District of Florida agreed with the Seminole Tribe, granting first a preliminary injunction and then summary judgment for the Tribe on the grounds that the Florida Bingo Statute was regulatory in nature and thus could not be enforced against the Tribe according to Bryan. [16] The lower court enjoined the Sheriff from enforcing the statute, allowing the Seminole Tribe's bingo hall to open in December 1979. [17]

Fifth Circuit Opinion

The Sheriff and the State of Florida appealed the District Court's decision to the Fifth Circuit, resulting in the opinion that is the subject of this Article. In this opinion, authored by Judge Lewis R. Morgan and joined by Judge Phyllis A. Kravitch, the Fifth Circuit affirmed the lower court's decision, finding for the Seminole Tribe on the same grounds. [18]

The Fifth Circuit agreed with the lower court's interpretation and application of the Supreme Court's Bryan decision, explaining that in this case and others, the issue under Bryan is "whether the statute in question represents an exercise of the state's regulatory or prohibitory authority." [19] According to the Fifth Circuit, a key consideration in this analysis is "whether the operation of bingo games is prohibited as against the public policy of the state or merely regulated by the state." [20] In this case, because the Florida Bingo Statute dictated that certain kinds of bingo events played for charitable, community, religious, or other similar purposes should still be permitted in the state, the Fifth Circuit concluded that the State of Florida must not consider the game of bingo "against the public policy of the state of Florida." [21] Instead, Florida's aim with regards to bingo appeared to be preventing abuses by imposing "certain limitations." [21] In other words, Florida sought to regulate bingo to prevent it from becoming a money-making business. [22] Thus, because the Bingo Statute did not prohibit bingo outright as against the public policy of Florida, the Fifth Circuit held that the Florida Bingo Statute was merely regulatory in nature even though it included potential penal sanctions for violation of the statute. [22] As a result, the Fifth Circuit held the Florida Bingo Statute could not be enforced by the Sheriff on the Seminole Tribe's reservation. [22]

Finally, the Fifth Circuit also clarified that the Florida Bingo Statute could not be enforced against either Indians or non-Indians on the reservation. [23] Although the Sheriff and the State of Florida argued that they should at least be permitted to apply the Bingo Statute against non-Indians playing bingo on the reservation, the Fifth Circuit held that such enforcement would still qualify as an impermissible infringement on the Tribe's own power to conduct bingo games without interference from Florida regulation, thereby violating Bryan. [24]

Fifth Circuit Dissent

Judge Paul Hitch Roney dissented from the majority's opinion in Seminole Tribe, arguing instead that Florida's Bingo Statute was clearly prohibitory in nature with regards to bingo played for commercial profit. [25] In fact, Judge Roney emphasized that the Seminole Tribe bingo parlor's great success was largely due to the universal prohibition of such bingo throughout the rest of the state. [25] Finally, because the Seminole Tribe failed to show that the effects of the bingo reservation were confined to the reservation, Judge Roney concluded that Florida had just as strong a reason for prohibiting such bingo playing on the reservation as off the reservation. [25] Thus, Judge Roney stated he would reverse the District Court's decision instead of affirm. [25]

Significance

Influence on the Development of Indian Gaming Law

Scholars often point to the Seminole Tribe's victory in this case as the birth of modern commercial Indian gaming. [1] [2] The Seminole Tribe was the first tribe to open a bingo hall on its reservation, and this case was the first to deal with a Public Law 280 state's efforts to put a stop to such gaming. [26] Thus, the Seminole Tribe's victory in this case was significant not only to them, but to many other tribes hoping to use high-stakes bingo parlors as a source of revenue and a means of attracting companies and jobs to the reservation. [27] [28] [29] The case signaled that tribes may be able to expand even a narrow exception in a state's gambling law "into a legal loophole for high-stakes, profit-generating" gambling on their reservations. [28]

Just a year after the Fifth Circuit's Seminole Tribe decision, a similar case called Barona Group v. Duffy arose in California. [30] Citing to Seminole Tribe and stating that they found it "persuasive," the Ninth Circuit held that California could not enforce its bingo laws on a tribe's reservation because California allowed bingo games in some contexts, meaning its statute was merely regulatory. [31] Decisions from at least six additional circuit later followed suit, upholding tribes' right to conduct high-stakes bingo on their reservations even though they were located within states that barred commercial gambling, but made exceptions for activities such as low-stakes charitable bingo games. [30] Thus, the Seminole Tribe case – and the cases from other circuits following it – "opened the floodgates" to high-stakes bingo on tribes' reservations in any one of the forty-five states that, by the mid-1980s, had exceptions in their bingo laws for low-stakes bingo games carried out by religious, charitable, educational, or other similar groups. [30]

Then in 1987, the Seminole Tribe case was cited in California v. Cabazon Band of Mission Indians , a seminal Supreme Court decision on Indian gaming. [32] In this case, the Court found that the prohibitory/regulatory distinction drawn in Seminole Tribe and other circuit cases was consistent with Bryan's construction of Public Law 280. [33] Applying a balancing test and reasoning similar to Seminole Tribe, the Court held that the State could not prevent the Cabazon Band of Mission Indians from continuing its bingo operations, even when faced with concerns about organized crime. [32] [34]

Finally, following the rapid expansion of bingo parlors on reservations after Seminole Tribe, the landmark Cabazon decision, and the resultant increasing pressure from states to provide for some means of state control over gaming on reservations, Congress passed the Indian Gaming Regulatory Act in 1988, the major federal law establishing the framework currently governing Indian gaming. [35] [32]

Impact on the Seminole Tribe

In the mid-1970s, the Seminole Tribe was in need of additional funds for its tribal government. Congress had adopted a new policy of tribal self-determination earlier in the decade, but although the new policy granted additional rights and powers to Tribes, congressional appropriations to Tribes had only declined. [36] The Tribe believed it needed to develop a large and robust revenue source that would decrease their reliance on federal government funding. [37] [38]

The Seminole Tribe first turned to opening smokeshops that sold tax-free cigarettes in 1976, generating about $1.5 million in revenue in the first few years. [37] This was a start, but the Tribe believed it needed more revenue to gain greater independence. So in 1979, the Tribe turned to building the bingo hall on its reservation instead. [37] [38]

Once the Seminole Tribe's bingo hall was permitted to open in December 1979, it proved to be the significant source of revenue the Tribe had hoped for. [37] [38] By a year after the bingo hall had opened, the hall was producing revenues of $1 million per month. Smokeshop revenue was also bolstered by the bingo business, reaching $800,000 per month. [39]

Since then, the Seminole Tribe has been a leader in developing and defending Indian gaming. [40] [38] By 2000, the Tribe operated 5 casinos, attracting an estimated 2 million visitors annually and contributing $65 million to the local economy. [38] By 2002, the Tribe's Gaming Department employed almost 2,000 individuals. [38] And in 2001, the tribe's budget exceeded $200 million, with over 95 percent of funds coming from casino revenues. [38] According to the Seminole Tribe's website, the Tribe's gaming enterprises and other subsequent business ventures "have brought the Seminoles closer to their stated goal of self-reliance." [41]

Related Research Articles

Native American gaming Gambling operations on Indian reservations in the United States

Native American gaming comprises casinos, bingo halls, and other gambling operations on Indian reservations or other tribal lands in the United States. Because these areas have tribal sovereignty, states have limited ability to forbid gambling there, as codified by the Indian Gaming Regulatory Act of 1988. As of 2011, there were 460 gambling operations run by 240 tribes, with a total annual revenue of $27 billion.

Nonintercourse Act Family of U.S. laws related to Native American tribal rights

The Nonintercourse Act is the collective name given to six statutes passed by the Congress in 1790, 1793, 1796, 1799, 1802, and 1834 to set Amerindian boundaries of reservations. The various Acts were also intended to regulate commerce between settlers and the natives. The most notable provisions of the Act regulate the inalienability of aboriginal title in the United States, a continuing source of litigation for almost 200 years. The prohibition on purchases of Indian lands without the approval of the federal government has its origins in the Royal Proclamation of 1763 and the Confederation Congress Proclamation of 1783.

<i>United States v. Washington</i> 1974 court case

United States v. Washington, 384 F. Supp. 312, aff'd, 520 F.2d 676, commonly known as the Boldt Decision, was a legal case in 1974 heard in the U.S. District Court for the Western District of Washington and the U.S. Court of Appeals for the Ninth Circuit. The case re-affirmed the rights of American Indian tribes in the state of Washington to co-manage and continue to harvest salmon and other fish under the terms of various treaties with the U.S. government. The tribes ceded their land to the United States but reserved the right to fish as they always had. This included their traditional locations off the designated reservations.

Seminole Tribe of Florida v. Florida, 517 U.S. 44 (1996), was a United States Supreme Court case which held that Article One of the U.S. Constitution did not give the United States Congress the power to abrogate the sovereign immunity of the states that is further protected under the Eleventh Amendment. Such abrogation is permitted where it is necessary to enforce the rights of citizens guaranteed under the Fourteenth Amendment as per Fitzpatrick v. Bitzer. The case also held that the doctrine of Ex parte Young, which allows state officials to be sued in their official capacity for prospective injunctive relief, was inapplicable under these circumstances, because any remedy was limited to the one that Congress had provided.

Indian Gaming Regulatory Act US federal law dictating regulations of American Indian gaming and casinos

The Indian Gaming Regulatory Act is a 1988 United States federal law that establishes the jurisdictional framework that governs Indian gaming. There was no federal gaming structure before this act. The stated purposes of the act include providing a legislative basis for the operation/regulation of Indian gaming, protecting gaming as a means of generating revenue for the tribes, encouraging economic development of these tribes, and protecting the enterprises from negative influences. The law established the National Indian Gaming Commission and gave it a regulatory mandate. The law also delegated new authority to the U.S. Department of the Interior and created new federal offenses, giving the U.S. Department of Justice authority to prosecute them.

Seminole Tribe of Florida

The Seminole Tribe of Florida is a federally recognized Seminole tribe based in the U.S. state of Florida. Together with the Seminole Nation of Oklahoma and the Miccosukee Tribe of Indians of Florida, it is one of three federally recognized Seminole entities. It received that status in 1957; today it has six Indian reservations in Florida.

Tribal-state compacts are declared necessary for any Class III gaming on Indian reservations under the Indian Gaming Regulatory Act of 1988 (IGRA). They were designed to allow tribal and state governments to come to a "business" agreement. A compact can be thought of as "negotiated agreement between two political entities that resolves questions of overlapping jurisdictional responsibilities Compacts affect the delicate power balance between states, federal, and tribal governments. It is these forms that have been a major source of controversy surrounding Indian gaming. Thus, it is understandable that the IGRA provides very detailed instructions for how states and tribes can make compacts cooperatively and also details the instructions for how the federal government can regulate such agreements.

California v. Cabazon Band of Mission Indians, 480 U.S. 202 (1987), was a United States Supreme Court case involving the development of Native American gaming. The Supreme Court's decision effectively overturned the existing laws restricting gaming/gambling on U.S. Indian reservations.

Sovereign immunity in the United States Legal protection of federal, state and tribal governments

In United States law, the federal government as well as state and tribal governments generally enjoy sovereign immunity, also known as governmental immunity, from lawsuits. Local governments in most jurisdictions enjoy immunity from some forms of suit, particularly in tort. The Foreign Sovereign Immunities Act provides foreign governments, including state-owned companies, with a related form of immunity—state immunity—that shields them from lawsuits except in relation to certain actions relating to commercial activity in the United States. The principle of sovereign immunity in US law was inherited from the English common law legal maxim rex non potest peccare, meaning "the king can do no wrong." In some situations, sovereign immunity may be waived by law.

Chickasaw Nation v. United States, 534 U.S. 84 (2001), was a case in which the Supreme Court of the United States held that Indian tribes were liable for taxes on gambling operations under 25 U.S.C. §§ 2701–2721.

The Cabazon Band of Mission Indians is a federally recognized tribe of Cahuilla Indians, located in Riverside County, California.

South Dakota v. Bourland, 508 U.S. 679 (1993), was a case in which the Supreme Court of the United States held that Congress specifically abrogated treaty rights with the Cheyenne River Sioux Tribe as to hunting and fishing rights on reservation lands that were acquired for a reservoir.

Bryan v. Itasca County, 426 U.S. 373 (1976), was a case in which the Supreme Court of the United States held that a state did not have the right to assess a tax on the property of a Native American (Indian) living on tribal land absent a specific Congressional grant of authority to do so.

Aboriginal title in the United States First country to recognize aboriginal title

The United States was the first jurisdiction to acknowledge the common law doctrine of aboriginal title. Native American tribes and nations establish aboriginal title by actual, continuous, and exclusive use and occupancy for a "long time." Individuals may also establish aboriginal title, if their ancestors held title as individuals. Unlike other jurisdictions, the content of aboriginal title is not limited to historical or traditional land uses. Aboriginal title may not be alienated, except to the federal government or with the approval of Congress. Aboriginal title is distinct from the lands Native Americans own in fee simple and occupy under federal trust.

Connecticut Indian Land Claims Settlement Indian Land Claims Settlement

The Connecticut Indian Land Claims Settlement was an Indian Land Claims Settlement passed by the United States Congress in 1983. The settlement act ended a lawsuit by the Mashantucket Pequot Tribe to recover 800 acres of their 1666 reservation in Ledyard, Connecticut. The state sold this property in 1855 without gaining ratification by the Senate. In a federal land claims suit, the Mashantucket Pequot charged that the sale was in violation of the Nonintercourse Act that regulates commerce between Native Americans and non-Indians.

Washington v. Confederated Bands and Tribes of the Yakima Indian Nation, 439 U.S. 463 (1979), was a case in which the Supreme Court of the United States held that the State of Washington's imposition of partial jurisdiction over certain actions on an Indian reservation, when not requested by the tribe, was valid under Public Law 280.

New Mexico v. Mescalero Apache Tribe, 462 U.S. 324 (1983), was a case in which the Supreme Court of the United States held that the application of New Mexico's laws to on-reservation hunting and fishing by nonmembers of the Tribe is preempted by the operation of federal law.

Oklahoma Tax Commission v. Sac & Fox Nation, 508 U.S. 114 (1993), was a case in which the Supreme Court of the United States held that absent explicit congressional direction to the contrary, it must be presumed that a State does not have jurisdiction to tax tribal members who live and work in Indian country, whether the particular territory consists of a formal or informal reservation, allotted lands, or dependent Indian communities.

United States v. John, 437 U.S. 634 (1978), was a case in which the Supreme Court of the United States held that lands designated as a reservation in Mississippi are "Indian country" as defined by statute, although the reservation was established nearly a century after Indian removal and related treaties. The court ruled that, under the Major Crimes Act, the State has no jurisdiction to try a Native American for crimes covered by that act that occurred on reservation land.

United States v. Antelope, 430 U.S. 641 (1977), was a United States Supreme Court case in which the Court held that American Indians convicted on reservation land were not deprived of the equal protection of the laws; (a) the federal criminal statutes are not based on impermissible racial classifications but on political membership in an Indian tribe or nation; and (b) the challenged statutes do not violate equal protection. Indians or non-Indians can be charged with first-degree murder committed in a federal enclave.

References

  1. 1 2 Nicholas S. Goldin, Note, Casting a New Light on Tribal Casino Gaming: Why Congress Should Curtail the Scope of High Stakes Indian Gaming, 84 Cornell L. Rev. 798, 810-11(1999).
  2. 1 2 John C. Kuzenski, The Paving Principle of Good Intentions? Calls for Reform of the Indian Gaming Regulatory Act and the Private Game Theory Equilibrium Opposing Them, 30 N.C. Cent. L. Rev. 168, 170-71 (2008).
  3. ↑ Seminole Tribe of Florida v. Butterworth, 491 F. Supp. 1015, 1016 (S.D. Fla. 1980) (hereinafter Seminole Tribe (District Court opinion)), aff'd, Seminole Tribe of Florida v. Butterworth, 658 F.2d 310 (5th Cir. 1981).
  4. 1 2 Seminole Tribe (District Court opinion), 491 F. Supp. at 1016.
  5. ↑ Goldin, supra note 1, at 810-11.
  6. ↑ Matthew L.M. Fletcher, The Seminole Tribe and the Origins of Indian Gaming, 9 FIU L. Rev. 255 (2014), https://digitalcommons.law.msu.edu/cgi/viewcontent.cgi?article=1543&context=facpubs, at 255.
  7. ↑ Fla. Stat. § 849.093. Repealed in 1992 by Laws 1991, c. 91-421, § 3 (eff. June 1, 1992).
  8. ↑ Seminole Tribe (District Court opinion), 491 F. Supp. at 1017.
  9. ↑ Seminole Tribe of Florida v. Butterworth, 658 F.2d 310, 311 (5th Cir. 1981) (hereinafter Seminole Tribe (5th Cir. opinion)), cert. denied, Butterworth v. Seminole Tribe of Florida, 455 U.S. 1020 (1982).
  10. ↑ Seminole Tribe (5th Cir. opinion), 658 F.2d at 311.
  11. 1 2 Seminole Tribe (5th Cir. opinion), 658 F.2d at 311-12, 31, 314.
  12. ↑ Seminole Tribe (5th Cir. opinion), 658 F.2d at 312.
  13. ↑ Pub. L. No. 83-280, 67 Stat. 588 (1953) (codified as amended at 18 U.S.C. § 1162, 25 U.S.C. §§ 1321-25, and 28 U.S.C. § 1360); see Seminole Tribe (5th Cir. opinion), 658 F.2d 312-13 (summarizing the impact of Public Law 280 on state jurisdiction over Indian reservation activity).
  14. ↑ Bryan v. Itasca County, 426 U.S. 373, 383 (1976) ("[I]f Congress in enacting Pub. L. 280 had intended to confer upon the States general civil regulatory powers . . . it would have expressly said so.").
  15. ↑ Seminole Tribe (5th Cir. opinion), 658 F.2d at 313-14.
  16. ↑ Seminole Tribe (District Court opinion), 491 F. Supp. at 1017, 1019-20.
  17. ↑ Seminole Tribe (District Court opinion), 491 F. Supp. at 1016 n. 2.
  18. ↑ Seminole Tribe (5th Cir. opinion), 658 F.2d at 312 ("[A]greeing with the lower court, we affirm its decision.").
  19. ↑ Seminole Tribe (5th Cir. opinion), 658 F.2d at 313 (quoting Bryan, 426 U.S. at 390).
  20. ↑ Seminole Tribe (5th Cir. opinion), 658 F.2d at 313.
  21. 1 2 Seminole Tribe (5th Cir. opinion), 658 F.2d at 314.
  22. 1 2 3 Seminole Tribe (5th Cir. opinion), 658 F.2d at 314-15.
  23. ↑ Seminole Tribe (5th Cir. opinion), 658 F.2d at 316-17.
  24. ↑ Seminole Tribe (5th Cir. opinion), 658 F.2d at 316.
  25. 1 2 3 4 Seminole Tribe (5th Cir. opinion), 658 F.2d at 317 (Roney, J., dissenting).
  26. ↑ Chris J. Thompson, Comment, Internet Gambling: A Road to Strengthening Tribal Self-Government and Increasing Tribal Self-Sufficiency While Protecting American Consumers, 37 Am. Indian L. Rev. 229, 232 (2013).
  27. ↑ William C. Sturtevant & Jessica R. Cattelino, Florida Seminole and Miccosukee, http://www.sscnet.ucla.edu/anthro/faculty/jcattelino/FloridaSeminoleandMiccosukee.pdf, at 446.
  28. 1 2 Goldin, supra note 1, at 812.
  29. ↑ Willard Steele, Seminoles Today, Seminole Tribe of Florida, https://www.semtribe.com/history/SeminolesToday.aspx ("The success of Seminole gaming against legal challenges opened the door for dozens of other American Indian tribes to follow suit.").
  30. 1 2 3 Thompson, supra note 34, at 232.
  31. ↑ Barona Group v. Duffy, 694 F.2d 1185, 1188 (9th Cir. 1982).
  32. 1 2 3 Kuzenski, supra note 2, at 172.
  33. ↑ California v. Cabazon Band of Mission Indians, 480 U.S. 202, 209-210 (1987).
  34. ↑ California v. Cabazon Band of Mission Indians, 480 U.S. 202, 220-22 (1987).
  35. ↑ Indian Gaming Regulatory Act (IGRA), Pub. L. 100-497 (1988) (codified at 25 U.S.C. § 2701 et seq.).
  36. ↑ Fletcher, supra note 4, at 262-63.
  37. 1 2 3 4 Fletcher, supra note 4, at 263-64.
  38. 1 2 3 4 5 6 7 Sturtevant & Cattelino, supra note 35, at 446.
  39. ↑ Fletcher, supra note 4, at 264.
  40. ↑ Fletcher, supra note 4, at 266.
  41. ↑ Willard Steele, Seminoles Today, Seminole Tribe of Florida, https://www.semtribe.com/history/SeminolesToday.aspx
This page is based on this Wikipedia article
Text is available under the CC BY-SA 4.0 license; additional terms may apply.
Images, videos and audio are available under their respective licenses.