La Plante v. Mohegan Tribal Gaming Authority

6 Am. Tribal Law 592, 3 G.D.R. 17
CourtMohegan Gaming Disputes Trial Court
DecidedMarch 17, 2006
DocketNo. GDTC-T-05-121-TBW
StatusPublished
Cited by2 cases

This text of 6 Am. Tribal Law 592 (La Plante v. Mohegan Tribal Gaming Authority) is published on Counsel Stack Legal Research, covering Mohegan Gaming Disputes Trial Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
La Plante v. Mohegan Tribal Gaming Authority, 6 Am. Tribal Law 592, 3 G.D.R. 17 (Mo. 2006).

Opinion

MEMORANDUM OF DECISION DEFENDANT’S MOTION TO DISMISS

WILSON, Judge.

This case involves two important questions concerning the sovereign immunity of The Mohegan Tribe of Indians of Connecticut: (1) whether the Tribe has waived its immunity from suit for damages by a former employee whose due process rights were found to have been violated after his termination and during the process of his appeal from that termination; and (2) whether the Indian Civil Rights Act [594]*594(“ICRA”) abrogated the tribe’s immunity from such suit. The Defendant has moved to dismiss.

I.

This case is a civil action for damages brought by a former employee of the Defendant under the Mohegan Torts Code MTO 2001-07 (“Torts Code”), and the Indian Civil Rights Act, 25 L.S.C. S 1202, Constitutional Rights (“ICRA”)1.

This case had its genesis in a prior decision of this court, LaPlante v. Office of the Director of Regulation, 2 G.D.R. 72, 5 Am. Tribal Law 316, 2004 WL 5660121 (2004) (Eagan, J.). A consideration of the facts and the conclusions of that case is necessary to an understanding of this one. That case (“LaPlante I”) may be summarized as follows:

“The plaintiff, Ralph LaPlante, appealed to this court from an order of the Mohegan Tribal Gaming Authority, (MTGC) Office of the Director of Regulations, revoking his gaming license for his alleged theft of casino chips by placing the chips in his toke box for tips. One of the main items of evidence introduced by the defendant at the administrative hearing was a videotape, which was used to show that Mr. LaPlante had misappropriated a toke to his own use. During the presentation of the evidence in this court, it was revealed that the tape had been edited and approximately 12 minutes was missing from the videotape. Mr. LaPlante argues that the missing twelve minutes would provide exculpatory evidence explaining the taking of the chips. Mr. LaPlante also claims that prior to the administrative hearing he had requested a copy of the videotape. Mr. LaPlante had an opportunity to view the videotape for the first time ai the administrative hearing held on April 23, 2003. In sustaining the plaintiffs appeal the court holds that the due process rights of the plaintiff were violated in the limited circumstance where an edited videotape was not given to the plaintiff prior to the administrative hearing.”

The court did not rule on the question whether the editing of the tape was suffi ciently prejudicial to the Plaintiff to invali date the prior ruling. Rather, the court found that the Plaintiff did have a right to view the videotape prior to the administrative hearing on his appeal from the lieenst revocation; that the Plaintiff did not havt an opportunity to do so; that substantial prejudice to the Plaintiff occurred; and that the Plaintiff was deprived of the opportunity to adequately respond to the charges which formed the basis of the revocation of his unemployment license. Because “adequate notice of evidence to be submitted against the Plaintiff is a fundamental requisite of due process rights under the Indian Civil Rights Act,” the court concluded that the Plaintiff had been deprived of such due process rights, the Plaintiffs appeal was sustained, and judg ment entered reversing the decision. 2 G.D.R. at 75, 5 Am. Tribal Law at 321-22. 2004 WL 5660121. The Defendant in that case, the Office of the Director of Regulation, appealed the decision to the Mohegan Gaming Disputes Court of Appeals. At the oral argument in this court on the Motion to Dismiss, it was disclosed that the appeal in LaPlante I was resolved by [595]*595the action of the Director of Regulation reinstating the Plaintiffs gaming license; by the Plaintiff agreeing not to pursue employment at the Mohegan Sun Casino; and by the Defendant’s withdrawal of its appeal. The appeal was withdrawn on January 27, 2005. This case was commenced by a writ, summons and complaint filed on August 26, 2005.

II.

The action filed in this court which is the subject of the Motion to Dismiss is in four counts, summarized as follows: “Count One: Negligence” alleges that the Defendant operates the Mohegan Sun Casino, a gaming facility owned by the Mohegan Tribe of Indians, a federally recognized Indian Tribe. The Plaintiff was employed as a poker dealer by the Defendant and on February 13, 2003, the Defendant accused the Plaintiff of stealing money. The Defendant referred these allegations to the Office of the Director of Regulation, and provided a surveillance tape of the Plaintiffs actions as proof of the Plaintiffs alleged theft. The Director of Regulation revoked the Plaintiffs gaming license, and as a result, the Plaintiff was terminated from his employment at the Casino. The Plaintiff alleged that the Defendant edited the tape and removed approximately twelve minutes from the tape in order to make it appear that the Plaintiff had committed the alleged theft, when, in fact, he had not. The Plaintiff then appealed the license revocation as set forth in Part I of this opinion. The Plaintiff further alleges that he suffered damages, including monetary damages, damage to his reputation, ¡and emotional distress. The Plaintiff alleges that these damages were caused by the negligence of the Defendant in several different respects, all relating to the editing of'the tape.

; “Count Two: Negligent Infliction of ’¡Emotional Distress” reiterates the allegations of Count One and alleges liability of the Defendant based on creating an unreasonable risk of causing emotional distress.

“Count Three: Violation of Indian Civil Rights Act and Due Process Claims” alleges that the conduct of the Defendant violated the Plaintiffs rights to due process of law as protected by the ICRA, and that the Plaintiff suffered damage as a result thereof.

“Count Four: Breach of the Implied Covenant of Good Faith and Farr Dealing,” was abandoned by the Plaintiff at oral argument on the Defendant’s Motion to Dismiss, and therefore, this court has not considered it.

The Defendant moved to dismiss the entire complaint. The Defendant asserted that the Defendant has not waived its sovereign immunity from suit as to any of the claims alleged, and that therefore, this court lacks jurisdiction. The Defendant also argued that the Plaintiffs claims were barred by the applicable statutes of limitation. Because the court concludes that the Defendant has not waived its immunity from suit in this case, the statute of limitations issue is not addressed.

III.

The Doctrine of Sovereign Immunitg

The Defendant in this case is the authorized agent of the Mohegan Tribe of Indians of Connecticut (“Tribe”), Mohegan Constitution, Art. XIII. The Tribe has received recognition as a tribal entity by the United States pursuant to Part 83 of Title 25 of the Code of Federal Regulations, and it is the successor in interest of the aboriginal entity known as the Mohegan Indian Tribe. 25 U.S.C. § 1775(a)(1) and (2). The Tribe is listed as a recognized entity in 62 Federal Register 55270 (1997). The Defendant is therefore im[596]*596mune from suit unless “Congress has authorized the suit or the Tribe has waived its immunity.” Kiowa Tribe v. Mfg. Technologies, Inc., 523 U.S. 751, 754, 118 S.Ct.

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Cite This Page — Counsel Stack

Bluebook (online)
6 Am. Tribal Law 592, 3 G.D.R. 17, Counsel Stack Legal Research, https://law.counselstack.com/opinion/la-plante-v-mohegan-tribal-gaming-authority-mohegangct-2006.