James v. Wampanoag Tribal Council of Gay Head, Inc.

499 N.E.2d 1213, 23 Mass. App. Ct. 122, 1986 Mass. App. LEXIS 1866
CourtMassachusetts Appeals Court
DecidedNovember 12, 1986
StatusPublished
Cited by6 cases

This text of 499 N.E.2d 1213 (James v. Wampanoag Tribal Council of Gay Head, Inc.) is published on Counsel Stack Legal Research, covering Massachusetts Appeals Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
James v. Wampanoag Tribal Council of Gay Head, Inc., 499 N.E.2d 1213, 23 Mass. App. Ct. 122, 1986 Mass. App. LEXIS 1866 (Mass. Ct. App. 1986).

Opinion

Greaney, C.J.,

The plaintiffs in these two consolidated actions claim to be Wampanoag Indians. They have brought an action in the Probate Court and another in the Superior Court in Suffolk County, alleging several violations of State [123]*123law, against the Wampanoag Tribal Council of Gay Head, Inc. (Council). The Council is representing the Gay Head Indian tribe in other litigation before the United States District Court for the District of Massachusetts. That litigation asserts an interest, on behalf of the tribe, to land on the Gay Head peninsula on the island of Martha’s Vineyard. In these actions, the plaintiffs are attempting to use State law to rid themselves of the Council’s representation and to block the impending settlement of the Federal land claims. Specifically, the plaintiffs allege in their two actions that the defendant has violated its corporate charter by asserting that it represents the tribe, and has misappropriated the plaintiffs’ rights to privacy by acting as their spokesman in the land litigation. Further, the plaintiffs assert in their complaints that a vote conducted by the defendant to ascertain whether a proposed settlement of the land claims should be approved was tainted by fraud and deceit. The plaintiffs and the defendant filed cross motions for summary judgment pursuant to Mass.R.Civ.P. 56, 365 Mass. 824 (1974). A judge of the Superior Court granted the defendant’s motion.

The long and tortuous history of the land dispute, and the inception of these actions, is set forth in two opinions of the United States Court of Appeals for the First Circuit, James v. Watt, 716 F.2d 71 (1st Cir. 1983), cert. denied sub nom. James v. Clark, 467 U.S. 1209 (1984), and James v. Bellotti, 733 F.2d 989 (1st Cir. 1984). There is no need to repeat the background which is adequately detailed in these two opinions.2

[124]*1241. In so far as relevant to this appeal, the defendant’s motion for summary judgment was predicated on two grounds: (1) the preclusion of the plaintiffs’ State claims by their failure to raise them in the longstanding Federal litigation; and (2) the lack of genuine triable issues of fact. The judge allowed the summary judgment for the defendant on the ground of issue preclusion.

The judge was correct. The original action brought by the defendant, Wampanoag Tribal Council of Gay Head, Inc. v. Gay Head, No. 74-5826 (D. Mass.) (Gay Head I), is twelve years old and was eight years old when the plaintiffs sought to intervene in it as a party. The Federal courts have acquired exclusive in rem and in personam jurisdiction over the final disposition of all the land claims. See James v. Bellotti, 733 F.2d at 993. Under the applicable statute, 25 U.S.C. § 177 (1982), a conclusive decision of the land claims necessarily requires determinations of (1) whether a tribe of Gay Head Indians exists, and (2) whether the defendant has authority to speak for that tribe. See James v. Watt, 716 F.2d at 72.

The second determination is the one involved in these cases. When they sought to intervene in the original action, the plaintiffs were aware of the fact that the defendant claimed that it, not the plaintiffs, was the exclusive spokesman for the tribe. The plaintiffs’ motion to intervene in the original Federal action alleged that they were indispensable parties and that a failure to join them could lead to loss of their rights, on issue preclusion principles, to act independently of the tribe or the defendant. Moreover, the pleadings in the original action (particularly a motion to dismiss filed and argued by the town of Gay Head on the ground that the tribe was not a party to the suit) squarely [125]*125put in issue the defendant’s authority to act as the tribe’s exclusive representative. That issue was adjudicated, favorably to the defendant here, by the denial of the town’s motion to dismiss.

Cognizant of these facts, the plaintiffs withdrew their appeal from the order denying intervention in the original action.3 Simultaneously they framed and litigated to a final adverse judgment a second Federal action without joining the defendant in that action, although it was clearly within their means to do so. See James v. Watt, supra. Thereafter, in the first State action commenced in the Probate Court (and then removed to the United States District Court for Massachusetts) they withdrew their appeal from the order dissolving the restraining order that was based on a challenge to the authority of the defendant to enter the settlement. See the history of James v. Bellotti, No. 83-3494 (D. Mass.) described at 733 F.2d 992. At the same time, the plaintiffs pressed the present State law claims in both the Probate and the Superior Courts.

We think the conclusion inescapable that the plaintiffs have engaged in a carefully calculated litigating strategy designed [126]*126to circumvent adverse decisions in the Federal courts and to seek new determinations from the State courts of issues that could have been raised, but purposely were not, in the Federal litigation. The plaintiffs sought intervention as of right in the original action. They knew, or should have known, when they withdrew their appeal from the order denying intervention, that their substantive rights would be concluded both on the issue of their standing and the authority of the defendant to represent the tribe. See Mayflower Dev. Corp. v. Dennis, 11 Mass. App. Ct. 630, 634 (1981), and cases cited. We are satisfied that the plaintiffs should be precluded from now claiming that their interests have not been adequately represented in the original action.4 See Cheyenne River Sioux Tribe of Indians v. United States, 338 F.2d 906, 911 (8th Cir. 1964), cert denied, 382 U.S. 815 (1965).

Under the standards set forth in Anderson v. Phoenix Inv. Counsel of Boston, Inc., 387 Mass. 444, 450-451 (1982), we also have no doubt that the Federal District Court judge who heard Gay Head I would have taken and decided, under the doctrine of pendent jurisdiction, the plaintiffs’ present State claims had it been decided on appeal that his order denying the plaintiffs’ intervention was erroneous. By the time intervention was sought, the judge had spent a considerable amount of time and effort in the litigation of Gay Head I. The judge would not have wanted his efforts to be attacked collaterally in State courts on grounds that could have fairly been decided in the litigation before him. By withdrawing their appeal of the denial of intervention a week after the decision in James v. Watt, supra, by litigating the latter action to final judgment [127]*127without joining the defendant, and by failing to pursue their appeal in James v. Bellotti, supra, the plaintiffs carefully sidestepped the interests of the Federal court in seeing the dispute decided once and for all.

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Bluebook (online)
499 N.E.2d 1213, 23 Mass. App. Ct. 122, 1986 Mass. App. LEXIS 1866, Counsel Stack Legal Research, https://law.counselstack.com/opinion/james-v-wampanoag-tribal-council-of-gay-head-inc-massappct-1986.