Sipp v. Buffalo Thunder, Inc.

CourtNew Mexico Supreme Court
DecidedJanuary 16, 2024
StatusUnpublished

This text of Sipp v. Buffalo Thunder, Inc. (Sipp v. Buffalo Thunder, Inc.) is published on Counsel Stack Legal Research, covering New Mexico Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Sipp v. Buffalo Thunder, Inc., (N.M. 2024).

Opinion

The slip opinion is the first version of an opinion released by the Chief Clerk of the Supreme Court. Once an opinion is selected for publication by the Court, it is assigned a vendor-neutral citation by the Chief Clerk for compliance with Rule 23-112 NMRA, authenticated and formally published. The slip opinion may contain deviations from the formal authenticated opinion.

1 IN THE SUPREME COURT OF THE STATE OF NEW MEXICO

2 Opinion Number:

3 Filing Date: January 16, 2024

4 NO. S-1-SC-39169

5 JEREMIAH SIPP a/k/a SAGE RADER, 6 and HELLA RADER,

7 Plaintiffs-Respondents, 8 v.

9 BUFFALO THUNDER, INC.; BUFFALO 10 THUNDER DEVELOPMENT AUTHORITY; 11 PUEBLO OF POJOAQUE; PUEBLO OF 12 POJOAQUE GAMING COMMISSION; and 13 POJOAQUE GAMING, INC., 14 Defendants-Petitioners.

15 ORIGINAL PROCEEDING ON CERTIORARI 16 David K. Thomson, District Judge

17 Rey-Bear McLaughlin, LLP 18 Daniel I.S.J. Rey-Bear 19 Timothy H. McLaughlin 20 Spokane, WA

21 for Petitioners

22 Valdez and White Law Firm, LLC 23 Timothy L. White 24 Albuquerque, NM

25 for Respondents 1 Rothstein Donatelli, LLP 2 Richard W. Hughes 3 Donna M. Connolly 4 Santa Fe, NM

5 for Amici Curiae Pueblos of Santa Ana and Santa Clara

6 Chestnut Law Offices, P.A. 7 Ann Berkley Rodgers 8 Albuquerque, NM 9 for Amicus Curiae Pueblo of Acoma

10 VanAmberg, Rogers, Yepa, Abeita, Gomez & Wilkinson, LLP 11 C. Bryant Rogers 12 David T. Gomez 13 Santa Fe, NM

14 for Amicus Curiae Taos Pueblo

15 Pueblo of Laguna 16 James M. Burson 17 Laguna, NM

18 for Amicus Curiae Pueblo of Laguna

19 Pueblo of Sandia 20 Steffani A. Cochran 21 Bernalillo, NM 22 for Amicus Curiae Pueblo of Sandia

23 Frye & Kelly, P.C. 24 Paul E. Frye 25 Albuquerque, NM 26 for Amicus Curiae Ohkay Owingeh 1 Sonosky, Chambers, Sachse, Mielke & Brownell, LLP 2 David C. Mielke 3 Albuquerque, NM 4 for Amici Curiae Pueblo of Isleta and San Felipe Enterprises

5 Laguna Development Corporation 6 Leander Bergen 7 Alicia Sanasac 8 Albuquerque, NM 9 for Amicus Curiae Laguna Development Corporation

10 University of New Mexico School of Law 11 Michael B. Browde 12 David J. Stout 13 Albuquerque, NM 14 for Amicus Curiae New Mexico Trial Lawyers Association 1 OPINION

2 BACON, Chief Justice.

3 {1} The instant case requires us to determine whether the jurisdiction shifting

4 from tribal court to state court authorized under Section 8(A) (“Policy Concerning

5 Protection of Visitors”) of New Mexico’s Tribal-State Class III Gaming Compact

6 (the Compact) 1 was terminated under the Compact’s own terms by either Pueblo of

7 Santa Ana v. Nash, 972 F. Supp. 2d 1254 (D.N.M. 2013), appeal dismissed, 10th

8 Cir. (13-2182 & 13-2191) (2014), or Navajo Nation v. Dalley, 896 F.3d 1196 (10th

9 Cir. 2018), cert. denied sub nom. McNeal v. Navajo Nation, 139 S. Ct. 1600 (2019).

10 The relevant terms of Section 8(A) provide that

11 [f]or purposes of this Section, any such claim [for bodily injury or 12 property damage] may be brought in state district court, including 13 claims arising on tribal land, unless it is finally determined by a state or 14 federal court that IGRA does not permit the shifting of jurisdiction over 15 visitors’ personal injury suits to state court.

16 (Emphasis added.)

1 The Tribal-State Class III Gaming Compact at issue in this case was signed by the Pueblo of Pojoaque in 2005 and is contained in the case record. The standard 2001, 2007, and 2015 compact language as approved by the Legislature is available at NMSA 1978, Ch. 11, Art. 13, Appx. (2023). See also N.M. Gaming Control Board, Tribal Compacts, https://www.gcb.nm.gov/gaming/tribal/tribal-compacts/ (last visited Dec. 29, 2023). 1 {2} Pueblo of Pojoaque and several Pueblo-owned entities (Petitioners) assert that

2 both Nash and Dalley terminated the jurisdiction shifting in Section 8(A) as each

3 case constitutes a “final[] determin[ation] by a state or federal court” that such

4 jurisdiction shifting is not permitted under the Indian Gaming Regulatory Act

5 (IGRA), 25 U.S.C. §§ 2701-2721. Accordingly, Petitioners argue for reversal of the

6 Court of Appeals’ opinion, which reversed the district court’s grant of Petitioners’

7 motion to dismiss for lack of subject matter jurisdiction. Jeremiah Sipp and Hella

8 Rader (Respondents) argue for affirmance, asserting that the relevant jurisdiction

9 shifting under Section 8(A) was not terminated by Nash or Dalley and thus the Court

10 of Appeals’ remand of their personal-injury tort claims to the district court for further

11 proceedings was proper.

12 {3} We reverse, holding under contract law that jurisdiction shifting under Section

13 8(A) of the Compact was terminated by Nash. We therefore do not reach the

14 secondary issue of whether state jurisdiction over such claims is permissible under

15 IGRA in light of Michigan v. Bay Mills Indian Community, 572 U.S. 782 (2014).

16 I. FACTUAL AND PROCEDURAL BACKGROUND

17 {4} IGRA creates the framework for states and Indian tribes to cooperate in

18 regulating on-reservation tribal gaming. Under IGRA, a tribal-state gaming compact

19 is required for an Indian tribe to have a Class III gaming facility, and the statute

2 1 “prescribes the matters that are permissible subjects of gaming-compact negotiations

2 between tribes and states.” Mendoza v. Isleta Resort & Casino, 2020-NMSC-006, ¶

3 14, 460 P.3d 467. In 2005 and again in 2017, the Pueblo of Pojoaque and the State

4 of New Mexico entered into the Compact. Section 8(A) of the Compact provides

5 that visitors to Indian casinos may bring their bodily injury and property damage

6 claims against tribal entities in state court unless a state or federal court finally

7 determines that IGRA does not permit the shifting of jurisdiction over those claims

8 to state court. This language terminating a visitor’s option to choose state court

9 jurisdiction is the subject of the instant dispute.

10 {5} Respondents filed a complaint for damages in state district court against

11 Petitioners Buffalo Thunder, Inc., Buffalo Thunder Development Authority, the

12 Pueblo of Pojoaque, the Pueblo of Pojoaque Gaming Commission, and Pojoaque

13 Gaming, Inc. The complaint alleged that in the course of his employment for Dial

14 Electric, Respondent Sipp was in the receiving area of the Buffalo Thunder casino

15 when his head struck a large electric garage-type door which was unexpectedly and

16 suddenly lowered by a casino employee. The complaint further alleged that

17 Petitioners’ negligence directly resulted in Respondent Sipp being “rendered

18 unconscious, causing him severe injuries, including but not limited to severe head

3 1 and spinal injuries.” Respondent’s claims for damages included related medical

2 costs and Respondent Hella Rader’s loss of consortium.

3 {6} Following a hearing, the district court granted Petitioners’ motion to dismiss

4 for lack of subject matter jurisdiction. The district court concluded that Respondents’

5 claims did not fall within Section 8(A), and that “[t]herefore, [Respondents] ha[d]

6 not established an express abrogation or waiver of [Petitioners’] sovereign immunity

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