Inyo County v. Paiute-Shoshone Indians of the Bishop Community
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Inyo County Inyo County () is a county in the eastern central part of the U.S. state of California, located between the Sierra Nevada and the state of Nevada. In the 2020 census, the population was 19,016. The county seat is Independence. Inyo County ...
v. Paiute-Shoshone Indians of the Bishop Community'', 538 U.S. 701 (2003), was a
United States Supreme Court The Supreme Court of the United States (SCOTUS) is the highest court in the federal judiciary of the United States. It has ultimate appellate jurisdiction over all U.S. federal court cases, and over state court cases that involve a point o ...
case.


Background

The
Bishop Paiute Tribe The Bishop Paiute Tribe, formerly known as the Paiute-Shoshone Indians of the Bishop Community of the Bishop Colony is a federally recognized tribe of Mono and Timbisha Indians of the Owens Valley, in Inyo County of eastern California.
of California owns and operates the Paiute Palace Casino. The Inyo County District attorney had three casino employees under suspicion of
welfare fraud Welfare, or commonly social welfare, is a type of government support intended to ensure that members of a society can meet basic human needs such as food and shelter. Social security may either be synonymous with welfare, or refer specifical ...
, and asked the casino for their employment records. The casino declined, stating that it was against their privacy policy. Upon finding probable cause, the district attorney obtained a search warrant, authorizing the search of employment records of those three casino employees. Subsequently, the district attorney asked for the records of six more employees. The tribe once again reiterated their privacy policy, but offered up for evidence the last page of each employee's welfare application. The district attorney refused the offer. To ward off additional searches, the tribe filed a suit against the district attorney and the county. They stated that their tribe's status as a sovereign made them immune to state processes under federal law and asserted that the state authorized the seizure of tribal records. The California district court dismissed the tribe's complaint, holding that the tribal sovereign immunity does not preclude the search and seizure of personnel records. In 2002, the decision was reversed, with the
Ninth Circuit The United States Court of Appeals for the Ninth Circuit (in case citations, 9th Cir.) is the U.S. federal court of appeals that has appellate jurisdiction over the U.S. district courts in the following federal judicial districts: * District ...
holding that the executing of a search warrant against the Paiute-Shoshone tribe interfered with their right to make their own laws, and be governed by them.


Decision

In a unanimous decision, the court vacated the decision of the
Ninth Circuit The United States Court of Appeals for the Ninth Circuit (in case citations, 9th Cir.) is the U.S. federal court of appeals that has appellate jurisdiction over the U.S. district courts in the following federal judicial districts: * District ...
. The court found that was only meant to protect private rights, not sovereign rights. And since the case rested entirely of the basis that the tribe's sovereign immunity was violated by the search warrant being issued, the tribe could not sue under section ยง1983.


See also

* Paiute-Shoshone Indians of the Bishop Community of the Bishop Colony * ''
Cherokee Nation v. Georgia ''Cherokee Nation v. Georgia'', 30 U.S. (5 Pet.) 1 (1831), was a United States Supreme Court case. The Cherokee Nation sought a federal injunction against laws passed by the U.S. state of Georgia depriving them of rights within its boundaries, but ...
'' * '' Worcester v. Georgia''


References


External links

* {{Populations of Native California Groups United States Constitution Article Three case law United States Supreme Court cases United States Supreme Court cases of the Rehnquist Court 2003 in United States case law United States Native American gaming case law United States tribal sovereign immunity case law Second Enforcement Act of 1871 case law History of Inyo County, California Paiute Mono Welfare fraud