Gardner v. Littlejohn

13 Am. Tribal Law 111
CourtHo-Chunk Nation Supreme Court
DecidedMay 8, 2015
DocketNo. SU 15-01
StatusPublished

This text of 13 Am. Tribal Law 111 (Gardner v. Littlejohn) is published on Counsel Stack Legal Research, covering Ho-Chunk Nation Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Gardner v. Littlejohn, 13 Am. Tribal Law 111 (hochunk 2015).

Opinion

DECISION

PER CURIAM.

This matter came before the full Court for Oral Argument on Thursday, April 2, 2015. Presiding over the Oral Argument were Justices Pro Tempore Joseph Hallo-ran and Mark Radcliffe and former Chief Justice Mary Jo B. Hunter. Present were Attorney William F. Gardner with his client, Rita A. Gardner and Ronald An-wash and Dr. Jeremy P. Rockman, pro se. [112]*112This matter is an appeal of a Trial Court Order (Dismissal for Lack of Subject Matter Jurisdiction) filed on November 26, 2014. The Appellant’s Initial Brief has been filed. The Appellees did not file a brief.

Based on the record before the Court, we reverse the Trial Court’s order dismissing the case for lack of jurisdiction. The Trial Court misinterpreted this Court’s decision in Gardner I to have extinguished the defamation cause of action found by the Ho Chunk Nation Traditional Court. The defamation cause of action recognized by the Traditional Court, which was not disturbed by this Court’s decision in Gardner I, is hereby reinstated and the matter is remanded for further proceedings consistent with this decision.

Procedural History

The procedural history of this case is lengthy and complicated and was the subject of an earlier decision of this Court. Gardner v. Littlejohn, et al., 11 Am. Tribal Law 400 (HCN S.Ct.2011) (Gardner I). The proceedings leading to Gardner I are summarized in that decision. The underlying claim involves an action for defamation and a defense that invoked an absolute privilege, referred to variously as a “warrior’s privilege” or “veteran’s privilege.” Neither the claim nor the defense is recognized under Ho-Chunk Nation Law. The Trial Court, pursuant to HCN R. Civ. P. 8(B), certified to the Traditional Court the question of whether defamation exists under Ho-Chunk custom and tradition, and the Traditional Court responded that it did. Gardner I, SU 11-02 at 5. As a result of the Traditional Court’s determination, the Trial Court granted partial summary judgment to the Plaintiff, but dismissed the Defendant’s Anwash, Rockman, and Kingsley based on a “veteran’s privilege,” Gardner v. Littlejohn, et al., 9 Am. Tribal Law 431 (2011), an issue that had not been certified to the Traditional Court. The Plaintiffs sought to reopen and amend the judgment, challenging the Trial Court’s application of the “veteran’s privilege.” That motion was denied and, on January 26, 2015, Plaintiff appealed from that part of the Trial Court’s decision that employed the veteran’s privilege. Notice of Appeal, Gardner v. Littlejohn, CV-10-47 (Jan. 26, 2015). On February 5, 2015, this Court accepted the appeal. Order Accepting Appeal, Gardner v. Littlejohn, SU 15-01 (Feb. 5, 2015).

On appeal, this Court reviewed the process by which the Trial Court consulted with the Traditional Court regarding whether there is a basis for in Ho-Chunk custom and tradition for a veteran’s privilege, the scope of the privilege, or who was customarily entitled to invoke the privilege. This Court held in Gardner I that the Trial Court’s consultation with the Traditional Court on that issue of a veteran’s privilege violated the Plaintiffs due process rights. Gardner I, SU 11-02 at 6. The matter was then remanded to the Trial Court for further proceedings consistent with that decision. Gardner I, SU 11-02 at 7.

On remand, the Trial Court issued an Order governing further proceedings on remand, and in that Order observed that “the Supreme Court overturned this Court’s adoption of a “veteran’s privilege” from a ruling of the Traditional Court due to a violation of the plaintiffs due process rights.” Gardner v. Littlejohn, CV 10-47 (March 27, 2012), citing Gardner I. The Trial Court, however, went further and, the without motion from the defendant’s or direction from this Court, determined that the Traditional Court’s determination regarding defamation violated due process under Gardner I. Gardner v. Littlejohn, CV 10-47 (March 27, 2012) at 6. As a [113]*113result of that ruling, the Trial Court determined to submit written questions from the parties to the Traditional Court, including the previously-decided question of defamation, and the question of the veteran’s privilege (Gardner v. Littlejohn, CV-HM7 (November 25, 2014) at 1-2) and to coordinate an on-the-record consultation with the parties and the Traditional Court.

The Traditional Court met with the parties, but that proceeding was not recorded and this Court cannot determine whether the Traditional Court made a decision at that meeting. The Traditional Court did not, however, issue any written response to the questions certified by the Trial Court, despite several written requests from the Trial Court. Gardner v. Littlejohn, CV-10-7 (November 25, 2014) at 2. The record does not reflect any effort by the Trial Court to meet again with the parties and the Traditional Court in joint session or any other effort to clarify the Traditional Court’s determination, other than the written inquires cited by the Trial Court in its decision below.

Based on the lack of written response from the Traditional Court on the certified questions, the Trial Court dismissed the Plaintiffs action, concluding that the Court lacked subject matter jurisdiction over the claim. The Court concluded that Gardner I “extinguished” the Traditional Court’s prior determination that a cause of action for defamation exists under Ho-Chunk Nation customs and traditions. Gardner v. Littlejohn, CV-10-47 (November 25, 2014) at 6-7, and that, absent direction from the Traditional Court, which the Court perceived it needed and had not received, the Court was without jurisdiction to proceed.

Standard of Review

This matter involves questions of law and as such this Court has utilized a de novo review for reviewing questions of law. Robert A. Mudd v. HCN Legislature, SU 03-02 (HCN S.Ct., April 8, 2003).

Discussion

In the Appeal, the Court is asked to review the Trial Court’s interpretation and implementation of this Court’s decision in Gardner I. Specifically, Appellant asserts the Trial Court incorrectly applied the Supreme Court decision and erred in ruling that the Gardner I extinguished or in any way altered the Traditional Court’s determination that a common law basis for a defamation claim was extinguished. This Court agrees that the Trial Court erred for the reasons stated below.

The Trial Court erred as a matter of law in its interpretation and application of this Court’s decision in Gardner I and that misinterpretation directly resulted in the subsequent Order of dismissal for lack of jurisdiction. On remand from Gardner I, the Trial Court rightly determined that “the Supreme Court overturned this Courts adoption of a veteran’s privilege ...” Gardner v. Littlejohn, CV 10-47 (March 27, 2012). However, when the Trial Court went further and determined that Gardner I “extinguished” the defamation cause of action, it erred as a matter of law.

Gardner I issued following an appeal by the Plaintiffs from the Trial Court’s determination that a “veteran’s privilege” exists under Ho Chunk Nation custom and tradition. Notice of Appeal, Gardner v. Little-john, CV 10-47 (Jan. 26, 2015).

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Related

Gardner v. Littlejohn
11 Am. Tribal Law 400 (Ho-Chunk Nation Supreme Court, 2011)
Gardner v. Littlejohn
9 Am. Tribal Law 431 (Ho-Chunk Nation Trial Court, 2011)

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Bluebook (online)
13 Am. Tribal Law 111, Counsel Stack Legal Research, https://law.counselstack.com/opinion/gardner-v-littlejohn-hochunk-2015.