Navajo Nation v. Department of the Interior

CourtDistrict Court, District of Columbia
DecidedSeptember 16, 2021
DocketCivil Action No. 2020-1093
StatusPublished

This text of Navajo Nation v. Department of the Interior (Navajo Nation v. 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
Navajo Nation v. Department of the Interior, (D.D.C. 2021).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

THE NAVAJO NATION,

Plaintiff,

v. No. 20-cv-1093 (DLF) U.S. DEPARTMENT OF THE INTERIOR, et al.,

Defendants.

MEMORANDUM OPINION

Before the Court are the plaintiff’s Motion for Summary Judgment, Dkt. 12, and the

government’s Cross-Motion for Summary Judgment, Dkt. 13. For the reasons below, the Court

will grant the plaintiff’s motion and deny the government’s motion.

I. BACKGROUND

A. Legal Background

“Congress enacted the Indian Self-Determination and Education Assistance Act

(“ISDEAA”) 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

Interior, 852 F.3d 1124, 1126 (D.C. Cir. 2017). Under that Act, Indian tribes may enter “self-

determination contract[s] . . . to plan, conduct, and administer programs” that the Secretary of the

Interior operates for their benefit. 25 U.S.C. § 5321(a)(1). To form such a contract, a tribe must

first propose terms to the Secretary. Id. § 5321(a)(2). From there, “the Secretary shall . . .

approve the proposal” within ninety days “unless” he “clearly demonstrates,” or supports with

“controlling legal authority,” one of the five showings listed in § 5321(a)(2). These grounds for rejecting the proposal include that the tribe’s “proposed project . . . cannot be properly completed

or maintained by the proposed contract,” id. § 5321(a)(2)(C), and that a tribe has requested funds

“in excess of [its] applicable funding level,” id. § 5321(a)(2)(D).

Upon entering a self-determination contract, tribes are entitled to IHS funding for both

“direct program expenses” and “contract support costs.” 25 U.S.C. § 5325(a)(3)(A). This

funding may be awarded through Annual Funding Agreements (AFAs), which “represent[] the

negotiated agreement of the Secretary to fund, on an annual basis, the programs, services,

activities and functions transferred to an Indian tribe.” 25 C.F.R. § 900.6. The process for

approving an AFA, like that of forming a self-determination contract, begins with a proposal

from the tribe to the Secretary. See id. § 900.32. If a proposed AFA is “substantially the same”

as the prior AFA, the Secretary “shall approve and add to the contract the full amount of funds to

which the contractor is entitled.” Id. Otherwise, the portions of the proposal that are not

“substantially the same” are subject to “declination criteria and procedures” that apply to self-

determination contracts. Id. Thus, the Secretary may decline to approve those portions “only . . .

for one of [the] five specific reasons” listed in 25 U.S.C. § 5321(a)(2). Id. § 900.22.

If the Secretary declines to approve a proposed AFA, the affected tribe may challenge the

Secretary’s decision in federal district court. See 25 U.S.C. § 5331(a); 25 C.F.R § 900.153. As

an alternative, the tribe may appeal the decision to the Interior Board of Indian Appeals (IBIA),

with the possibility of further review in federal court. See 25 C.F.R. § 900.158; 25 U.S.C. §

5331(a). Finally, the tribe may request an informal conference to be “conducted by a designated

representative of the Secretary.” 25 C.F.R. § 900.155(c). If the tribe elects to participate in an

informal conference, the presiding representative will issue a written report that “summarizes

what happened at the [] conference and [contains] a recommended decision.” Id. § 900.156(a).

2 If a tribe is “dissatisfied” with that decision, it may appeal within thirty days to the IBIA. Id.

§ 900.156(b). Otherwise, “the recommended decision becomes final.” Id. § 900.157.

B. Factual Background

The Navajo Nation is a federally recognized Indian tribe that operates a forestry

management program pursuant to a self-determination contract. See Pl.’s Statement of Material

Facts Not in Dispute ¶ 1, Dkt. 12. Under that contract, the Nation receives funding through

Annual Funding Agreements (AFAs) and Successor Annual Funding Agreements (SAFAs). Id.

¶ 2. On September 28, 2019, the Nation submitted a proposed SAFA for contract year 2020,

which requested $737,745 to cover direct program expenses. Compl. Ex. A at 33, Dkt. 1-1. The

SAFA also proposed modifying which forest management functions the contract covers. See id.

at 22–26. Under its terms, the Nation would be permitted to “operate a woodlot to produce

firewood for sale to the public” and would be exempt from several reporting requirements that

were contained in the 2019 SAFA. Id. at 25.

On December 19, 2019, the Secretary denied the Nation’s proposed SAFA. See Compl.

Ex. B, Dkt. 1-2. To support that denial, the Secretary found that the Nation requested funding

“in excess of the . . . funding level” available under the parties’ contract. Id. at 3 (citing 25

C.F.R. § 900.22(d)). He also found that the SAFA’s subject matter could not “be properly

completed or maintained by the proposed contract,” 25 U.S.C. § 5321(a)(2)(C). Id. at 2–3.

On January 7, 2020, the Nation requested the review of that decision in an informal

conference. See Compl. Ex. C at 3, Dkt. 1-3. Following that conference, the Secretary’s

representative directed that the Nation receive $717,736.77 for direct program expenses under its

contract. Id. at 4. The representative also found that the 2020 SAFA was not “substantially

different” from the 2019 SAFA, which required approving its terms irrespective of the

3 declination criteria in 25 U.S.C. § 5321(a)(2). Id. at 7. Finally, the representative found that,

even if the declination criteria applied, the Secretary failed to show that the subject matter of the

SAFA could not “be properly completed or maintained by the proposed contract.” Id. (quoting

25 U.S.C. § 5321(a)(2)(C)). Having explained those findings, the representative then directed

the parties to “convene and make a good faith effort, on a government-to-government basis, to

develop a CY2020 SAFA that complies with the statutory requirements at” 25 U.S.C. § 5329.

Id. at 6. In the meantime, the representative ordered, the 2019 SAFA would remain in place. Id.

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