Shoshone Bannock Tribes of the Fort Hall Reservation v. United States of America

CourtDistrict Court, D. Idaho
DecidedMay 29, 2019
Docket4:18-cv-00285
StatusUnknown

This text of Shoshone Bannock Tribes of the Fort Hall Reservation v. United States of America (Shoshone Bannock Tribes of the Fort Hall Reservation v. United States of America) is published on Counsel Stack Legal Research, covering District Court, D. Idaho primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Shoshone Bannock Tribes of the Fort Hall Reservation v. United States of America, (D. Idaho 2019).

Opinion

UNITIED STATES DISTRICT COURT FOR THE DISTRICT OF IDAHO SHOSHONE-BANNOCK TRIBES OF THE FORT HALL RESERVATION., Case No. 4:18-cv-00285-DCN

Plaintiff, MEMORANDUM DECISION AND ORDER v.

UNITED STATES OF AMERICA; et al.,

Defendants.

I. INTRODUCTION Pending before the Court is Plaintiff Shoshone-Bannock Tribes of the Fort Hall Reservation’s (“Tribes”) Motion to Stay Proceedings. Dkt. 53. Having reviewed the record and briefs, the Court finds that the facts and legal arguments are adequately presented. Accordingly, in the interest of avoiding further delay, and because the Court finds that the decisional process would not be significantly aided by oral argument, the Court will address the motion without oral argument. Dist. Idaho Loc. Civ. R. 7.1(d)(1)(B). For the reasons outlined below, the Court finds good cause to GRANT the Tribes’ Motion to Stay. II. BACKGROUND The Tribes brought this action against the United States and other Defendants relating to lands in Pocatello, Idaho. The United States granted easements on these reservation lands for railroad company use beginning in the late 1800s. The tribes now want to regain control of this land. The United States filed a Motion to Dismiss the Tribes’ Amended Complaint (Dkt. 41), arguing that the Tribes had already waived and released their claims against the United States through a settlement agreement entered in the District of Columbia as a

Joint Stipulation and Order. Dkt. 41-1, at 12. The parties disagree on the scope of the settlement and whether the Tribes have waived their current claims. To resolve the issue, the Tribes have filed a motion seeking clarification on the issue with the D.C. District Court which retains jurisdiction over the interpretation and enforcement of the settlement stipulation and order. The Tribes now seek to stay proceedings in this Court until the

D.C. District Court renders a decision on the interpretation thereof. III. LEGAL STANDARD The Court “has broad discretion to stay proceedings as an incident to its power to control its own docket.” Clinton v. Jones, 520 U.S. 681, 706-707 (1997) (citing Landis v. N. Am. Co., 299 U.S. 248, 254 (1936)). “A trial court may, with propriety, find it is

efficient for its own docket and the fairest course for the parties to enter a stay of an action before it, pending resolution of independent proceedings which bear upon the case.” Leyva v. Certified Grocers of Cal., Ltd., 593 F.2d 857, 863-64 (9th Cir. 1979). Determining whether to grant a motion to stay “calls for the exercise of judgment, which must weigh competing interests and maintain an even balance.” Landis, 299 U.S. at 254-

55. “When considering a motion to stay, the district court should consider three factors: (1) the potential prejudice to the non-moving parties; (2) the hardship and inequity to the moving party if the action is not stayed; and (3) the judicial resources that would be saved.” In re Micron Tech., Inc. Secs. Litig., No. CV-06-085-S-BLW, 2009 WL 10678270, at *2 (D. Idaho Dec. 7, 2009). IV. ANALYSIS The Court is first concerned with the issue of jurisdiction. The United States

argues that this Court has concurrent jurisdiction over the interpretation of the settlement agreement because the D.C. District court only retained exclusive jurisdiction over the enforcement of the agreement, not its interpretation. However, the plain language of the joint stipulation and order says the D.C. District Court would retain jurisdiction “for the limited purpose of interpreting and enforcing” the settlement. Dkt. 55-1. The use of the

word “and” separating “interpreting” and “enforcing” denotes that the D.C. District Court retains exclusive control over both interpretation and enforcement. Therefore, according to the plain language of the Joint Stipulation and Order, the D.C. Court has exclusive jurisdiction over the question of whether the claims were waived. Further, both an enforcement action and a request for interpretation of the Joint

Stipulation and Order require the examination and application of the Joint Stipulation and Order. In other words, as the Tribes point out, “judicial interpretation is enforcement.” Dkt. 54, at 3. Thus, the D.C. District Court has exclusive jurisdiction over the interpretation—as well as the enforcement—of the settlement agreement. Furthermore, when a court retains jurisdiction of a settlement agreement in this way, it is exclusive. See

Flanagan v. Arnaiz, 143 F.3d 540 (9th Cir. 1998) (“The context of the retention jurisdiction, a provision for future enforcement of a settlement order, implies that the retention was meant to be exclusive.”). Defendants1 cite Larson v. Clark County, No. 2:11-cv-879-JCM (PAL), 2012 WL 1900946 (May 24, 2012) in which summary judgment was granted because of a prior waiver and release of claims. But that case came before the same court in which the

settlement had been brought. Thus, it is easily distinguishable from this case where one Court—the D.C. District Court—presided over the settlement agreement, and a second, distinct Court—the undersigned Court—has been asked to interpret that agreement. Next, Defendant cites Erlichman v. Stater Bros. Markets, NO. 10-cv-01803-CJC (PJWx) 2012 WL 12887512 (S.D. Cal. Mar. 29, 2012). That case, however, is likewise unpersuasive as

the settlement agreement at issue was a union’s “voluntary quit” settlement, was written under union procedure, and jurisdiction was not reserved by any court. Finally, Defendant cites In re Waste Mgmt., Inc. Sec. Litig., No. 97 C 7709, 2003 WL 1463585, *2 (N.D. Ill. Mar. 19, 2003), a case that is not binding authority on the Court and is otherwise distinguishable. As the Tribes correctly note, in In re Waste Mgmt, “It was the

court where the settlement agreement and judgment were entered that rendered a decision on whether the settlement agreement precluded prosecution of a lawsuit in a separate district court case. It was not the [other] district court . . . .” Dkt. 57, at 4. Here, the D.C. District Court has not decided that question. Thus, the Court finds that the D.C. District court has exclusive jurisdiction over the interpretation of the settlement agreement.

The United States further argues that the doctrine of comity ought to persuade the

1 The “United States Defendants”—i.e., the United States and all agency directors—are the only Defendants who oppose the Tribes’ Motion to Stay. Defendants City of Pocatello and Union Pacific Railroad Company do not oppose the Motion. See Dkts. 56, 58. D.C. District Court to defer to this Court’s interpretation of the settlement agreement because the issue of waiver of claims under the settlement was brought up by the United States in this Court first (Dkt. 55, at 4 (citing Pacesetter Systems, Inc. v. Medtronic, Inc.,

678 F.2d 93, 94-96 (9th Cir. 1982)). The case the United States relies upon is, again, distinguishable as the two courts in that matter had concurrent jurisdiction. Here, the D.C. Court has exclusive jurisdiction and so the doctrine of comity does not apply. The Court will briefly discuss various arguments raised by the parties for, or against, granting a stay in this case.

A. Judicial Economy If the D.C. District Court renders a decision on the interpretation of the settlement agreement, it will simplify this Court’s role in deciding the rest of the case. If the D.C.

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Related

Landis v. North American Co.
299 U.S. 248 (Supreme Court, 1936)
Clinton v. Jones
520 U.S. 681 (Supreme Court, 1997)
Dependable Highway Express, Inc. v. Navigators Ins.
498 F.3d 1059 (Ninth Circuit, 2007)
Lockyer v. Mirant Corp.
398 F.3d 1098 (Ninth Circuit, 2005)
Flanagan v. Arnaiz
143 F.3d 540 (Ninth Circuit, 1998)

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