Prairie Band Potawatomi Nation v. Jackson County Sheriff's Office

CourtDistrict Court, D. Kansas
DecidedFebruary 10, 2025
Docket5:24-cv-04066
StatusUnknown

This text of Prairie Band Potawatomi Nation v. Jackson County Sheriff's Office (Prairie Band Potawatomi Nation v. Jackson County Sheriff's Office) is published on Counsel Stack Legal Research, covering District Court, D. Kansas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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Prairie Band Potawatomi Nation v. Jackson County Sheriff's Office, (D. Kan. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF KANSAS

PRAIRIE BAND POTAWATOMI NATION, ) ) Plaintiff, ) CIVIL ACTION ) v. ) No. 24-4066-KHV ) JACKSON COUNTY SHERIFF TIM MORSE, ) in his official capacity, ) ) and ) ) JACKSON COUNTY SHERIFF’S OFFICE, ) ) Defendants. ) ____________________________________________)

MEMORANDUM AND ORDER AND ORDER TO SHOW CAUSE On July 19, 2024, Prairie Band Potawatomi Nation filed a complaint against Tim Morse, Sheriff of Jackson County, Kansas, in his official capacity and the Jackson County Sheriff’s Office. Plaintiff alleges that defendants unlawfully exercised civil jurisdiction within the Nation’s Reservation and seeks a declaratory judgment that within the Reservation, defendants lack (1) civil-regulatory jurisdiction and (2) authority to interfere with the Nation’s lawful exercise of civil-regulatory jurisdiction. Plaintiff also seeks permanent injunctive relief prohibiting defendants from (1) interfering with the Nation’s lawful exercise of its civil-regulatory jurisdiction and (2) exercising unlawful civil-regulatory jurisdiction within the Reservation. This matter is before the Court on the Motion To Dismiss (Doc. #10) which Sheriff Morse filed September 3, 2024. For reasons stated below, the Court sustains in part defendant’s motion to dismiss and orders plaintiff to show cause in writing why the Court should not dismiss plaintiff’s claim for injunctive relief for lack of standing under Article III, U.S. Const., art. III, and the Declaratory Judgment Act, 28 U.S.C. § 2201 et seq. Legal Standards Defendant seeks to dismiss plaintiff’s complaint under Rules 12(b)(2) and 12(b)(6) of the Federal Rules of Civil Procedure. I. Rule 12(b)(2) – Lack Of Personal Jurisdiction When defendant files a motion to dismiss for lack of personal jurisdiction under

Rule 12(b)(2), plaintiff must establish personal jurisdiction over defendant. Rockwood Select Asset Fund XI (6)-1, LLC v. Devine, Millimet & Branch, 750 F.3d 1178, 1179–80 (10th Cir. 2014). At these preliminary stages of litigation, plaintiff’s burden to establish personal jurisdiction is light. AST Sports Sci., Inc. v. CLF Distrib. Ltd., 514 F.3d 1054, 1056 (10th Cir. 2008). To defeat the motion, plaintiff need only make a prima facie showing of personal jurisdiction. Id. Plaintiff can do so by showing facts, via affidavit or other written materials, that if true would support jurisdiction over defendant. Id. When evaluating the prima facie case, the Court must resolve all factual disputes in favor of plaintiff. Id. II. Rule 12(b)(6) – Failure To State A Claim

In ruling on a motion to dismiss for failure to state a claim under Rule 12(b)(6), the Court assumes as true all well-pleaded factual allegations and determines whether they plausibly give rise to an entitlement to relief. Ashcroft v. Iqbal, 556 U.S. 662, 679 (2009). To survive a motion to dismiss, a complaint must contain sufficient factual matter to state a claim which is plausible— and not merely conceivable—on its face. Id. at 679–80; Bell Atl. Corp. v. Twombly, 550 U.S. 544, 555 (2007). In determining whether a complaint states a plausible claim for relief, the Court draws on its judicial experience and common sense. Iqbal, 556 U.S. at 679. The Court need not accept as true those allegations which state only legal conclusions. See id.; United States v. Herring, 935 F.3d 1102, 1110 (10th Cir. 2019). Plaintiff bears the burden of framing its claims with enough factual matter to suggest that it is entitled to relief; it is not enough to make threadbare recitals of a cause of action accompanied by conclusory statements. See Twombly, 550 U.S. at 556. Plaintiff makes a facially plausible claim by pleading factual content from which the Court can reasonably infer that defendant is liable for the alleged misconduct. Iqbal, 556 U.S. at 678. Plaintiff must show more than a sheer possibility that defendant has acted

unlawfully—it is not enough to plead facts that are “merely consistent” with defendant’s liability. Id. (quoting Twombly, 550 U.S. at 557). A pleading which offers labels and conclusions, a formulaic recitation of the elements of a cause of action or naked assertions devoid of further factual enhancement will not stand. Id. Similarly, where the well-pleaded facts do not permit the Court to infer more than mere possibility of misconduct, the pleading has alleged—but has not “shown”—that the pleader is entitled to relief. Id. at 679. The degree of specificity necessary to establish plausibility and fair notice depends on context, because what constitutes fair notice under Rule 8(a)(2), Fed. R. Civ. P., depends on the type of case. Robbins v. Oklahoma, 519 F.3d 1242, 1248 (10th Cir. 2008).

Factual Background Plaintiff’s complaint alleges as follows: The Prairie Band Potawatomi Nation—a federally recognized Indian tribe—exercises governmental authority over a reservation in northeastern Kansas. Under the Potawatomi Law and Order Code, the Nation exercises civil-regulatory jurisdiction over all businesses within the Reservation. Title 10 of the Code establishes the Prairie Band Potawatomi Tax Commission, which imposes a tobacco excise tax, gross receipts sales tax and motor fuels tax. Title 13 of the Code governs business licensing within the Reservation and authorizes sanctions for non- compliance. One possible sanction is a cease and desist order requiring the business to immediately cease doing business where the non-compliance poses an immediate threat to the peace, safety, morals or general welfare of residents of the Reservation. In January of 2024, Wamego Store LLC, doing business as Snak Atak Travel Plaza—a non-Indian owned company located on fee land1 within the Reservation—applied to the Tax Commission for four licenses: a business license, a tobacco retailer license, a liquor retailer license

and a tribal motor fuels retailer license. In those applications, Snak Atak consensually submitted to the jurisdiction of the Nation and agreed to pay tobacco and sales taxes to the Tax Commission, to provide certain sales and inventory reports to the Tax Commission and to be bound by all laws of the Nation. In addition, in its Tobacco Retailer License application, Snak Atak agreed to pay the Tax Commission for Tribal Tax Stamps affixed on individual packs of cigarettes and to take all reasonable precautions to ensure the security and integrity of the Tribal Stamp. Apart from Snak Atak’s consent to the Nation’s regulatory and taxation authority, the Nation has inherent civil-regulatory jurisdiction over sales of tobacco, alcohol, motor fuel and other goods within the Reservation. Congress has delegated authority to the Nation to regulate

alcohol sales within the Reservation, and the State of Kansas has agreed that the Nation will regulate all sales of cigarettes within the Reservation. Snak Atak’s alcohol and tobacco sales have a direct effect on the Nation’s health and welfare. In January and February of 2024, the Tax Commission issued to Snak Atak the four business licenses which it had requested.

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