Fort McDermitt Paiute and Shoshone Tribe v. Price

CourtDistrict Court, District of Columbia
DecidedSeptember 26, 2019
DocketCivil Action No. 2017-0837
StatusPublished

This text of Fort McDermitt Paiute and Shoshone Tribe v. Price (Fort McDermitt Paiute and Shoshone Tribe v. Price) 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
Fort McDermitt Paiute and Shoshone Tribe v. Price, (D.D.C. 2019).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

FORT MCDERMITT PAIUTE AND SHOSHONE TRIBE,

Plaintiff, v. Civil Action No. 17-837 (TJK)

ALEX M. AZAR et al.,

Defendants.

MEMORANDUM OPINION

The Indian Self-Determination and Education Assistance Act provides eligible Indian

tribes with the option to contract with federal agencies to directly assume operations of services

and programs that those agencies ordinarily provide. This action concerns just such an

arrangement. The Fort McDermitt Paiute and Shoshone Tribe negotiated with the Indian Health

Service to take over operations of two health programs that that agency had been providing. But

the parties reached an impasse on several issues, including, as relevant here, the appropriate

amount of federal funding. The Tribe, as the statute provides, submitted a “final offer,” which

the agency rejected in full. The Tribe now sues.

Before the Court are the parties’ cross-motions for summary judgment. For the reasons

that follow, the Court will grant the Tribe’s motion and deny the agency’s motion. 1

1 In ruling on these motions, the Court considers all relevant parts of the record, including: ECF No. 1 (“Compl.”); ECF No. 26 (“Joint SOF”); ECF No. 29-1 (“Tso Decl.”); ECF No. 31 (“Pl.’s MSJ”); ECF No. 33-1 (“Defs.’ MSJ”); ECF No. 33-3 (“Ward Decl.”); ECF No. 36 (“Pl.’s Opp’n”); ECF No. 37 (“Defs.’ Opp’n”); and ECF Nos. 11–12 (Joint Appendix, with citations designated as “AR__”). Background

A. Statutory Framework

Congress passed the Indian Self-Determination and Education Assistance Act of 1975

(ISDEAA or “the Act”), 25 U.S.C § 5301 et seq., “to help Indian tribes assume responsibility for

programs or services that a federal agency would otherwise provide to the tribes’ members.”

Navajo Nation v. U.S. Dep’t of the Interior, 852 F.3d 1124, 1126 (D.C. Cir. 2017). Title V of the

Act authorizes a tribe to enter into “self-governance compacts” with the Indian Health Service

(IHS), an agency of the Department of Health and Human Services (HHS), to shift responsibility

to the tribe to operate health services ordinarily provided by IHS. See 25 U.S.C. §§ 5381–99.

As part of that arrangement, IHS must negotiate and enter into a written funding

agreement with the contracting tribe for the continued provision of federal funds for the

transferred services and programs. See id. § 5385. Relevant to the dispute here, Title V entitles

a contracting tribe to a recurring award not less than the amount “the Secretary [of HHS] would

have otherwise provided for the operation of the programs or portions thereof for the period

covered by the contract.” 25 U.S.C. § 5325(a)(1); see also id. §§ 5385(g), 5388(c); Defs.’ MSJ at

4.2 That amount is often called a tribe’s “Secretarial amount” or “base amount,” and it is

generally not subject to reduction in future years. See Seneca Nation of Indians v. U.S. Dep’t of

Health & Human Servs., 945 F. Supp. 2d 135, 143 (D.D.C. 2013); Defs.’ MSJ at 4. Indeed, the

Act specifically states that that amount “shall not be reduced by the Secretary in subsequent

years except pursuant to” a limited set of reasons. 25 U.S.C. § 5325(b)(2). The statute

nevertheless provides that, “[n]otwithstanding any other provision in [the Act], the provision of

funds under [the Act] is subject to the availability of appropriations and the Secretary is not

2 The IHS is vested with the Secretary’s authority under 25 U.S.C. § 1661.

2 required to reduce funding for programs, projects, or activities serving a tribe to make funds

available to another tribe or tribal organization under [the Act].” Id. § 5325(b).

ISDEAA directs IHS to negotiate in good faith with a contracting tribe. See id.

§§ 5385(a), 5387(e). But if IHS and a tribe cannot agree on the terms of a self-governance

compact or a funding agreement, including funding amounts, the tribe may submit a “final offer”

to IHS presenting its position on the issues in dispute. Id. § 5387(b). Within 45 days, IHS “shall

review and make a determination with respect to such offer.” Id. If IHS determines to reject a

final offer in whole or in part, it must provide timely written notice to the tribe. Id. § 5387(c).

But a rejection may be based only on the four grounds enumerated in the statute:

(i) the amount of funds proposed in the final offer exceeds the applicable funding level to which the Indian tribe is entitled under this subchapter;

(ii) the program, function, service, or activity (or portion thereof) that is the subject of the final offer is an inherent Federal function that cannot legally be delegated to an Indian tribe;

(iii) the Indian tribe cannot carry out the program, function, service, or activity (or portion thereof) in a manner that would not result in significant danger or risk to the public health; or

(iv) the Indian tribe is not eligible to participate in self-governance under section 5383 of [Title V].

Id. § 5387(c)(1)(A). And the written notice must “contain[] a specific finding that clearly

demonstrates” the ground(s) relied on or “is supported by a controlling legal authority.” Id. “In

the absence of a timely rejection of the offer, in whole or in part, made in compliance with

subsection (c) of this section, the offer shall be deemed agreed to by [IHS].” Id. § 5387(b).

The ISDEAA provides federal district courts with original jurisdiction over claims

against the Secretary arising under Title V, including a tribe’s claim that IHS improperly rejected

its final offer. See 25 U.S.C. § 5331(a); see also id. § 5387(c)(1)(C) (providing that a tribe may

3 forgo an administrative appeal and “directly proceed to initiate an action in a Federal district

court pursuant to section 5331(a)”); id. § 5391(a) (confirming that section 5331(a) applies to

compacts and funding agreements under Title V). For purposes of a civil action challenging

IHS’s rejection of a final offer, the Act expressly provides that IHS “shall have the burden of

demonstrating by clear and convincing evidence the validity of the grounds for rejecting the offer

(or a provision thereof) made under subsection (b) of [§ 5387].” Id. § 5387(d); see also id.

§ 5398 (providing generally that the Secretary has the burden in any civil action to show by clear

and convincing evidence “(1) the validity of the grounds for the decision made; and (2) that the

decision is fully consistent with provisions and policies of [Title V]”). And the Act further

authorizes the reviewing court to “order appropriate relief including money damages, injunctive

relief . . . , or mandamus . . . (including immediate injunctive relief to reverse a declination

finding . . . ).” Id. § 5331(a).

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