INYO COUNTY v. PAIUTE-SHOSHONE INDIANS

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Case Basics
Docket No. 
02-281
Petitioner 
Inyo County
Respondent 
Paiute-Shoshone Indians
Advocates
(Argued the cause for the respondents)
(Argued the cause for the petitioners)
(Department of Justice, argued the cause, as amicus curiae, supporting the petitioners in part and the respondents in part)
Term:
Facts of the Case 

During an investigation of welfare fraud, the Inyo County Sheriff's office requested personnel files from a casino owned by the Paiute-Shoshone Indian tribe. When the request was denied, the Sheriff's office obtained a warrant to search for the records at the casino. After the search, the tribe sued, claiming that it was a violation of their sovereign immunity. The district court ruled for Inyo County; a 9th Circuit Court of Appeals panel reversed, ruling for the Paiute-Shoshone tribe.

Question 

Does a federally recognized tribe qualify as a "person" who may sue under 42 USC section 1983? Does a tribe's suit qualify for federal-court jurisdiction because it arises under some federal law other than section 1983?

Conclusion 
Decision: 9 votes for Inyo County, 0 vote(s) against
Legal provision: Reconstruction Civil Rights Acts (42 USC 1983)

No; the Court did not answer the second question. In a 9-0 opinion delivered by Justice Ruth Bader Ginsburg, the Court held that, in the situation presented, the Tribe does not qualify as a "person" who may sue under section 1983 to vindicate the sovereign right it here claims. The Court reasoned that section 1983 was designed to secure private rights against government encroachment, not to advance a sovereign's prerogative to withhold evidence relevant to a criminal investigation. Regarding the second question, the Court concluded that whether the Tribe's suit qualifies for federal-court jurisdiction because it arises under some federal law other than section 1983 was an issue that required additional addressing and remanded the question. Justice John Paul Stevens filed an opinion concurring in the judgment.

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INYO COUNTY v. PAIUTE-SHOSHONE INDIANS. The Oyez Project at IIT Chicago-Kent College of Law. 12 December 2014. <http://www.oyez.org/cases/2000-2009/2002/2002_02_281>.
INYO COUNTY v. PAIUTE-SHOSHONE INDIANS, The Oyez Project at IIT Chicago-Kent College of Law, http://www.oyez.org/cases/2000-2009/2002/2002_02_281 (last visited December 12, 2014).
"INYO COUNTY v. PAIUTE-SHOSHONE INDIANS," The Oyez Project at IIT Chicago-Kent College of Law, accessed December 12, 2014, http://www.oyez.org/cases/2000-2009/2002/2002_02_281.