Lytton Rancheria of California v. United States Department of the Interior

CourtDistrict Court, District of Columbia
DecidedMarch 27, 2026
DocketCivil Action No. 2025-0535
StatusPublished

This text of Lytton Rancheria of California v. United States Department of the Interior (Lytton Rancheria of California v. United States Department of the 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
Lytton Rancheria of California v. United States Department of the Interior, (D.D.C. 2026).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

LYTTON RANCHERIA OF CALIFORNIA, et al.,

Plaintiffs,

v. Civil Action No. 1:25-cv-00535 (CJN)

UNITED STATES DEPARTMENT OF THE INTERIOR, et al.,

Defendants.

ORDER

The government moves to transfer this case, ECF 18, and Plaintiffs move to stay it, ECF

26. For the reasons that follow, the Court grants Plaintiffs’ motion.1

Plaintiffs, three “Southern Pomo Indian tribes with strong historical connections to Sonoma

County, California,” sued the Department of Interior, Bureau of Indian Affairs, and their officers

for “rushing to take land into trust and to approve a casino project proposed by the Koi Nation of

Northern California.” ECF 14 ¶¶ 1, 4. The government moved to transfer the case to the Northern

District of California because that district encompasses the land at issue and other suits challenging

Interior’s action were already proceeding there. ECF 18. While that motion was pending, the

district court in one of those cases granted partial summary judgment against the government and

vacated the Interior action at issue. See Federated Indians of Graton Rancheria v. U.S. Dep’t of

the Interior, No. 3:24-cv-8582, 2025 WL 2522376, at *15 (N.D. Cal. Sept. 2, 2025). Plaintiffs

1 The Court declines—at this time—to rule on the government’s motion to transfer, ECF 18, because it concludes that a stay is warranted. Nothing in this Order, however, shall be construed to affect the merits of that motion. 1 now move to stay this case pending the conclusion of the appeals there, explaining that “[i]f

appellate proceedings are completed in Graton and the district court’s orders are not reversed or

vacated, Plaintiffs would voluntarily dismiss this case.” ECF 26 at 2. The government opposes

the stay on the grounds that the request is premature and that the court in the Northern District of

California should be the one to decide whether to stay the case. ECF 28.

When considering whether to stay a case, “the district court, in ‘the exercise of judgment,’

[must] ‘weigh competing interests and maintain an even balance,’ between the court’s interests in

judicial economy and any possible hardship to the parties.” Belize Soc. Dev. Ltd. v. Gov’t of Belize,

668 F.3d 724, 732–33 (D.C. Cir. 2012) (quoting Landis v. N. Am. Co., 299 U.S. 248, 254–55

(1936)). Plaintiffs have met their burden to establish that a temporary stay of this case is warranted.

Considerations of judicial economy favor a stay because how the Ninth Circuit resolves those

appeals will likely affect the resolution of several issues, including whether transfer is appropriate,

who should prevail on the merits, and whether Plaintiffs will continue to pursue this case at all.

See Basardh v. Gates, 545 F.3d 1068, 1069 (D.C. Cir. 2008) (observing that stays are “[o]ften”

issued “in light of other pending proceedings that may affect the outcome of the case”); Hulley

Enters. Ltd. v. Russian Fed’n, 211 F. Supp. 3d 269, 276 (D.D.C. 2016) (“Th[e] power to issue a

stay may be appropriately exercised where a separate proceeding bearing upon the case is

pending.”). And the government has failed to establish that it would face “even a fair possibility”

of hardship from such a stay. Landis, 299 U.S. at 255. Indeed, since briefing concluded on the

stay motion here, the government requested—and was granted—a stay in one of the other related

cases in the Northern District of California. See California v. U.S. Dep’t of Interior, No. 3:25-cv-

3850, 2026 WL 412133, at *1–2 (N.D. Cal. Feb. 13, 2026). The Court therefore concurs with that

2 court’s conclusion that “a stay would significantly advance the orderly course of justice.” Id. at

*1.

Accordingly, it is hereby

ORDERED that Plaintiffs’ motion to stay, ECF 26, is GRANTED; and it is further

ORDERED that the Parties shall file a Joint Status Report every 90 days apprising the

Court of developments in proceedings in other courts that might have some bearing on this case;

and it is further

ORDERED that the Parties shall file a Joint Status Report that proposes next steps in this

case within 30 days of the issuance of the Ninth Circuit’s mandate in the Graton appeals; and it is

further

ORDERED that this case is STAYED pending a further order of the Court upon its review

of the post-mandate Joint Status Report.

DATE: March 27, 2026 ________________________ CARL J. NICHOLS United States District Judge

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Related

Landis v. North American Co.
299 U.S. 248 (Supreme Court, 1936)
Basardh v. Gates
545 F.3d 1068 (D.C. Circuit, 2008)
Hulley Enterprises Ltd. v. Russian Federation
211 F. Supp. 3d 269 (District of Columbia, 2016)

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