Reservation Business Services v. Albert

7 Navajo Rptr. 123
CourtNavajo Nation Supreme Court
DecidedMarch 16, 1995
DocketNo. SC-CV-05-94
StatusPublished

This text of 7 Navajo Rptr. 123 (Reservation Business Services v. Albert) is published on Counsel Stack Legal Research, covering Navajo Nation Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Reservation Business Services v. Albert, 7 Navajo Rptr. 123 (navajo 1995).

Opinion

OPINION

Opinion delivered by

YAZZIE, Chief Justice.

This is an original proceeding to answer five certified questions from the Tuba City District Court. Jurisdiction is based upon the Navajo Nation Supreme Court’s supervisory control over the trial courts. The questions posed are of first impression, and they address a common legal remedy which affects all trial courts. Given the nature of the issues, this Court exercises its discretionary jurisdiction to provide guidance. The questions are of material importance to the law of the Navajo Nation, and they are issues of substantial public interest.

I

The facts of the certified questions appear in the Tuba City District Court’s certification and they are stated below.

In 1989, Austin and Elizabeth Albert, the respondents in the Tuba City case, purchased a 1979 Redman New Moon mobile home from Leisure Development. The sale is governed by a retail installment contract and security agreement which Leisure Development assigned to Security Pacific Housing, a finance company. Security Pacific assigned its interests under the agreement to Reservation Business Services, the plaintiff in the Tuba City suit. Reservation Business Services’ primary business is the repossession of secured personal property.

Reservation Business Services filed its repossession action in the Tuba City District Court on July 30, 1993. The action is based upon 7 N.T.C. § 607(2) (1968), which prohibits the repossession of secured personal property within the Navajo Nation without the written consent of the debtor in possession or an order of a court in “an appropriate legal proceeding.” The plaintiff relies upon the Rules of Repossession of Personal Property Proceedings (1982), which establishes the “appropriate” legal proceeding in our legal system.

On September 24, 1993, the respondents moved for dismissal of the action [124]*124pursuant to Rule 12(b)(3) of the Navajo Rules of Civil Procedure. That rule provides that the defense of improper venue for an action may be raised in a motion to dismiss. The ground for the motion is that the mobile home is located in the St. Michaels Chapter of the Navajo Nation, which is approximately 150 miles east of Tuba City. The certification does not state, but we assume, that the respondents reside in the mobile home at St. Michaels. The plaintiff responds that venue, or the proper place to hear the case, lies in Tuba City, because of a demand letter to bring the account current made there.

The certification does not state the parties’ contentions regarding the proper • procedural rules for repossession actions, but it does conclude that there are questions about the validity of the 1982 repossession rules.

II

The trial court poses five questions of law, which we restate to better frame them for resolution. They are:

1. Which court rules apply to repossession actions, the 1982 Rules of Repossession Proceedings, the 1989 Rules of Civil Procedure, or both?

2. What is the proper venue or judicial district for repossession proceedings where the property or parties are located within a particular judicial district, and what is the remedy under our rules where an action is brought in the wrong judicial district?

3. What is the rule for defaults in repossession proceedings?

III

In 1968, the Navajo Nation Council addressed an issue of great importance to the consumers of the Navajo Nation. The general law of the United States, enshrined in the Uniform Commercial Code, allows self-help repossession of personal property when there is a default under a purchase agreement. In other words, a creditor has a general right to repossess secured property without notice to the debtor when the creditor determines the purchase agreement is broken by the debtor. The Navajo Nation Council, in Resolution No. CF-26-68 (February 7, 1968), declared the public policy of the Navajo Nation that self-help repossession of secured personal property is illegal, and that secured creditors must obtain the written consent of the debtor prior to repossession or obtain a court order permitting repossession. The preamble to the resolution declares that a creditor or security holder must be in “strict compliance” with the statute. Id. Preamble, § 2. The Council declared that the proper remedy for repossession actions is the common law action of replevin. Id. § 52(b).

In 1969, the Navajo Nation Council revisited the issue and declared that the purpose of our law is “to prevent violence and breach of the peace in the repossession of personal property....” Resolution No. CJN-53-69 (June 4, 1969), Preamble at § 5.

[125]*125The supervised repossession law was popular with Indian nations, and several other jurisdictions adopted it. It was not popular with creditors. We note that perhaps more than any other Navajo Nation statute, our repossession law has been the pretext for federal court challenges, comity disputes in surrounding states, and litigation within the Navajo Nation. Although the Navajo Nation Council has full authority to regulate commercial transactions within our territorial jurisdiction, dissatisfied lenders and collection agencies continue to resist our repossession law and our consumer protection policy.

One such challenge was pending in the federal courts when the 1982 repossession rules were adopted by the Judicial Conference of the Navajo Nation. On July 16,1981, the Office of the Navajo Nation General Counsel reported that our statute, 7 N.T.C. § 609, had survived a challenge in the U.S. District Court for the District of Arizona, Babbit Ford, Inc., and Gurley Motors v. Navajo Tribe, 519 F. Supp. 418, aff’d in part, rev. in part, 710 F.2d 587 (9th Cir. 1983), cert. denied 466 U.S. 926 (1984), but that an appeal by the plaintiffs in that action was possible. Navajo Law Journal 4000 (1982). The statute, at 7 N.T.C. § 607(2), did not state the “appropriate legal proceeding” for a repossession order, but the Council declared its intent to provide the common law remedy of replevin in Section 2(b) of the 1968 resolution.

“Replevin is one of the most ancient and well-defined writs known to the common law.” 66 Am. Jur. 2d Replevin § 1 (1973). “Replevin is a proceeding by which the owner or one who has a general or special property in the chattel taken or detained seeks to recover possession of that specific chattel, the recovery of damages being only an incident thereto.” Id. § 2. It is a possessory action where a plaintiff with the right of possession to personal property seeks the return of the property or damages. Id. § 3.

The Navajo Nation’s general counsel suggested that the Navajo Nation’s interest in its repossession law could be better defended on appeal if its courts clearly defined the procedure for repossession actions. The Navajo Nation Courts have the authority to adopt rules of “pleading, practice, and procedure” to regulate proceedings before the courts. 7 N.T.C. § 601. Courts have both the inherent and statutory power to define the procedures to be used by judges, practitioners and the public to implement judicial jurisdiction. See, Weinstein, Rule-making by the Courts, The Improvement of the Administration of Justice 127-135 (Klein, ed., 6th ed. 1981).

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