Cherokee Nation v. United States Department of Interior

CourtDistrict Court, District of Columbia
DecidedMarch 21, 2024
DocketCivil Action No. 2020-2167
StatusPublished

This text of Cherokee Nation v. United States Department of Interior (Cherokee Nation v. United States Department of Interior) is published on Counsel Stack Legal Research, covering District Court, District of Columbia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Cherokee Nation v. United States Department of Interior, (D.D.C. 2024).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

THE CHEROKEE NATION et al.,

Plaintiffs,

v. Civil Action No. 20-2167 (TJK) UNITED STATES DEPARTMENT OF THE INTERIOR et al.,

Defendants.

MEMORANDUM OPINION & ORDER

This case is about the validity of certain tribal-gaming compacts governed by the Indian

Gaming Regulatory Act. But before the parties could get to litigating the merits, a dispute broke

out over who may properly represent the State of Oklahoma. Until now, Governor J. Kevin Stitt—

sued in his official capacity, which makes Oklahoma the real party in interest—has been repre-

sented by retained counsel. Now, Oklahoma’s Attorney General, Gentner F. Drummond, seeks to

assert his authority to “take and assume control” of the defense of the state’s interests, as he argues

an Oklahoma statute permits. He has also moved to certify the question of whether he may do so

to the Oklahoma Supreme Court. Regrettably, despite the further delay this will cause in resolving

the case, for the reasons explained below the Court will do so on its own initiative.

I. Background

The Court assumes familiarity with the background of this case and summarizes it only

briefly. Plaintiffs are four Native American tribes that each operate casinos in Oklahoma. They

sued in August 2020, seeking to invalidate tribal-gaming compacts entered into by Governor Stitt

with four other Native American tribes, which were then approved by the inaction of the U.S.

Secretary of the Department of the Interior under the Indian Gaming Regulatory Act, 25 U.S.C. § 2701 et seq. Plaintiffs sued three sets of defendants: (1) the Department of the Interior (and related

federal officials there); (2) Governor Stitt, in his official capacity; and (3) the leaders of the tribes

who entered into the compacts with Governor Stitt. Plaintiffs assert, among other things, that

Governor Stitt violated Oklahoma law when he entered into the compacts. ECF No. 104 ¶¶ 2–3.

Even before the suit was filed, Attorney General Drummond’s predecessor expressed the view in

a legal opinion that Governor Stitt did not have the authority to enter into two of the compacts. Id.

¶ 89.

In late November 2022, the Court resolved the Department of the Interior’s motion to dis-

miss, granted Plaintiffs’ motion to dismiss a counterclaim, and denied various other motions. See

ECF No. 157. The Court set a briefing schedule to govern the production of the administrative

record and summary judgment briefing. See Minute Order of Jan. 3, 2023. In April 2023, Plain-

tiffs moved to compel the Department of the Interior to complete the administrative record by

producing certain documents, which the parties briefed over the course of a few months.

Not long after, in July 2023, Attorney General Drummond sought to notice his appearance

on behalf of Governor Stitt. Until then, Governor Stitt had been represented by retained private

counsel. But in a five-page notice of appearance, Attorney General Drummond explained that

because the State of Oklahoma is the real party in interest, and because Governor Stitt, through his

retained counsel, has “inexplicably abrogated his constitutional duties in this case,” he was exer-

cising his statutory authority “to take and assume control of the defense of the State’s interests in

this case” as provided by Oklahoma law. See ECF No. 176 at 1, 3; Okla. Stat. tit. 74, § 18b(A)(3).

Attorney General Drummond also represented that the Oklahoma Supreme Court had “clearly and

unambiguously” already ruled that “the Governor had no authority to unilaterally execute the com-

pacts at issue in this case”—citing Treat v. Stitt, 473 P.3d 43 (Okla. 2020) and Treat v. Stitt, 481

2 P.3d 240 (Okla. 2021)—and so continuing to defend them violated his “constitutional duty to

faithfully execute Oklahoma law.” ECF No. 176 at 3. Attorney General Drummond also attached

to his filing letters from the Speaker of the Oklahoma House of Representatives and the President

Pro Tempore of the Oklahoma Senate, purporting to request on behalf of their bodies that he in-

tervene in this case. See ECF Nos. 176-1, 176-2.

In response, Governor Stitt, through his private counsel, moved to strike Attorney General

Drummond’s appearance, as well as that of Oklahoma’s Solicitor General, who also sought to

enter his appearance “[a]t the request of the Oklahoma Attorney General.” ECF No. 177. Gover-

nor Stitt accused Attorney General Drummond of trying to “hijack” the case for political purposes.

ECF No. 178 at 3. According to Governor Stitt, Attorney General Drummond lacks the statutory

authority to act as he suggests, and his attempt to do so violates the Oklahoma Constitution as well.

Id. Further, Governor Stitt argued, Attorney General Drummond’s reliance on the Speaker’s and

President Pro Tempore’s letters is misplaced, because those legislative bodies may not authorize

Attorney General Drummond’s actions, and even if they could, letters from individual legislators

would not do the trick. Id. at 4.

About a month after briefing on Governor Stitt’s motion to strike was complete, Attorney

General Drummond moved to certify the question of whether he may “take and assume control”

of the defense of the state’s interests in this case to the Oklahoma Supreme Court, in part, because

there is no controlling state case law on the matter. ECF No. 183. Governor Stitt opposed the

motion, arguing that the Attorney General lacks standing to file it, and even if he had standing,

certification is inappropriate. See ECF No. 186.

II. Legal Standards

A federal court may only certify a question to a state court “to the extent authorized by

state law.” In re Vitamins Antitrust Litig., No. 99-mc-197 (TFH), 2000 WL 1524912, at *1 (D.D.C.

3 July 14, 2000). The relevant Oklahoma statute provides: “The Supreme Court and the Court of

Criminal Appeals may answer a question of law certified to it by a court of the United States . . .

if the answer may be determinative of an issue in pending litigation in the certifying court and

there is no controlling decision of the Supreme Court or Court of Criminal Appeals, constitutional

provision, or statute of this state.” Okla. Stat. tit. 20, § 1602. The Oklahoma Supreme Court has

confirmed that it has the power to answer such questions. See White Star Petroleum, LLC v.

MUFG Union Bank, N.A., 480 P.3d 887, 889 (Okla. 2020) (“This Court is vested with discretion-

ary authority to review questions of law certified to it by a court of the United States, so long as

(1) the answer would be dispositive of an issue in pending litigation in the certifying court; and (2)

there is no established and controlling law on the subject matter.”). The certified question need

not be “dispositive of the cause”; rather, “[a]ll that is required for [the Oklahoma Supreme Court]

to answer a certified question is that the response be determinative of a single issue in the cause

and that no controlling state law exist.” Siloam Springs Hotel, LLC v. Century Sur. Co., 392 P.3d

262, 266 (Okla. 2017).

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