The Duwamish Tribe v. Haaland

CourtDistrict Court, W.D. Washington
DecidedJanuary 30, 2025
Docket2:22-cv-00633
StatusUnknown

This text of The Duwamish Tribe v. Haaland (The Duwamish Tribe v. Haaland) is published on Counsel Stack Legal Research, covering District Court, W.D. Washington primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
The Duwamish Tribe v. Haaland, (W.D. Wash. 2025).

Opinion

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3 4 5 UNITED STATES DISTRICT COURT WESTERN DISTRICT OF WASHINGTON 6 AT SEATTLE 7 THE DUWAMISH TRIBE and CECILE CASE NO. 2:22-cv-633-JNW HANSEN, in her capacity as the 8 Chairwoman of the Duwamish Tribal ORDER Council, 9 Plaintiffs, 10 v. 11 DEB HAALAND, U.S. Secretary of the 12 Interior, BRYAN NEWLAND, Assistant Secretary of Indian Affairs, U.S. 13 DEPARTMENT OF THE INTERIOR, BUREAU OF INDIAN AFFAIRS, 14 OFFICE OF FEDERAL ACKNOWLEDGMENT, UNITED 15 STATES OF AMERICA,

16 Defendants. 17 18 1. INTRODUCTION 19 For nearly 50 years, Plaintiffs have sought federal recognition as an Indian 20 Tribe under Part 83 of Title 25 of the Code of Federal Regulations, 25 C.F.R. 21 Part 83 (“Part 83”), which lays out the process for recognition. Defendant United 22 States Department of the Interior (“Department”) declined to acknowledge 23 Plaintiffs under older versions of Part 83 because Plaintiffs did not meet all the 1 criteria for recognition. So Plaintiffs sued the Department, challenging its ultimate 2 decision and alleging, among other things, that the Department violated Plaintiffs’

3 equal protection and due process rights by refusing to consider their petition under 4 the most recent version of Part 83—the “2015 regulations.” Dkt. No. 2 ¶¶ 134–135. 5 Now, without admitting error, the Department moves for voluntary remand to 6 consider Plaintiffs’ petition under the 2015 regulations. Dkt. No. 73. But Plaintiffs 7 say that further administrative proceedings are a waste of time and would only lead 8 to another denial of recognition. The Court disagrees.

9 Plaintiffs have repeatedly requested the Department consider their petition 10 under the 2015 regulations, arguing that doing so would lead to recognition. The 11 Department now wishes to do just that—“in good faith, and [with] no predetermined 12 outcome”—while allowing Plaintiffs to submit new evidence in support of their 13 petition. Dkt. No. 86 at 10. True, the Department stops short of promising a 14 “positive determination on remand,” but there is no evidence that its remand 15 request is an empty gesture or made in bad faith. Dkt. No. 86 at 10. And the

16 Department’s commitment to a changed approach on remand presents a real 17 possibility of a different outcome. This is enough to justify remand. 18 As a result, the Court REMANDS this matter to the Department to consider 19 Plaintiffs’ petition, and any new supporting evidence, under the 2015 regulations. 20 The Court DENIES the other remaining motions, Dkt. Nos. 55 and 85. 21

22 23 1 2. BACKGROUND 2 This case has a long factual and procedural history, and many parts of the

3 record are in dispute. The Court does not provide a comprehensive history of the 4 case here, but instead recounts the background relevant to the question of remand. 5 2.1 The Federal acknowledgment process generally. 6 Tribes who are “acknowledged” by the federal government enjoy rights and 7 privileges unavailable to other indigenous groups. Kahawaiolaa v. Norton, 386 F.3d 8 1271, 1273 (9th Cir. 2004) (“Federal recognition affords important rights and 9 protections to Indian tribes, including limited sovereign immunity, powers of self- 10 government, the right to control the lands held in trust for them by the federal 11 government, and the right to apply for a number of federal services.”). Historically, 12 “the federal government recognized American Indian Tribes on a case-by-case 13 basis.” Id. Then, “[i]n 1978, [the Department] promulgated regulations establishing 14 a uniform procedure for ‘acknowledging’ American Indian Tribes[.]” Agua Caliente 15 Tribe of Cupeño Indians of Pala Rsrv. v. Sweeney, 932 F.3d 1207, 1214 (9th Cir. 16 2019) (citing Kahawaiolaa, 386 F.3d at 1273; 25 U.S.C. § 9). These regulations are 17 known as Part 83, or the Part 83 process. Under the original Part 83 process, 18 petitioning tribes had to meet seven criteria: 19 (a) the group has been identified as an American Indian entity on a substantially continuous basis from historical times to the present, (b) a 20 substantial portion of the group inhabits a distinct area or lives in a community viewed as American Indian and distinct from other 21 populations in the area, (c) the group has maintained tribal political influence or other authority over its members as an autonomous entity 22 from historical times until the present, (d) the group has a governing document, (e) the group’s membership is composed of individuals who 23 1 descend from a historical Indian tribe, (f) the group’s membership is composed of persons who are not members of an acknowledged tribe, 2 and (g) the group’s status as a tribe has not been terminated or otherwise precluded by congressional legislation. 3 Hansen v. Salazar, No. C08-0717-JCC, 2013 WL 1192607, at *1 (W.D. Wash. Mar. 4 22, 2013) (citing 25 C.F.R. § 83.7 (1982)). Department historians and 5 anthropologists review each petition to determine whether it meets the requisite 6 Part 83 criteria. Kahawaiolaa, 386 F.3d at 1274. 7 The Department revised the Part 83 process in 1994. See Procedures for 8 Establishing that an American Indian Group Exists as an Indian Tribe, 59 Fed. 9 Reg. 9280 (Feb. 25, 1994) (codified at 25 C.F.R. § 83). The procedures for processing 10 a petition were substantially the same under the original and 1994 regulations. 11 Hansen, 2013 WL 1192607, at *2. But the 1994 regulations also permitted 12 “petitioners who present ‘substantial evidence of unambiguous [f]ederal 13 acknowledgment’ to proceed under a modified set of criteria” under 25 C.F.R. § 14 83.8. Id. 15 The Department revised the regulations again in 2015. See Federal 16 Acknowledgment of American Indian Tribes, 80 Fed. Reg. 37,862 (July 1, 2015) 17 (codified at 25 C.F.R. pt. 83). The 2015 regulations maintained the same basic 18 criteria, but ushered in several changes regarding the types of acceptable evidence. 19 For example, while the 1994 regulations required identification as an Indian tribe 20 by external sources, the 2015 regulations allow petitioners to rely on evidence of 21 “[i]dentification as an Indian entity by the petitioner itself.” Compare 25 C.F.R. § 22 83.7(a)(1)-(6) (1994) with 25 C.F.R. § 83.11(a)(1)-(7) (2015). And while the 1994 23 1 regulations considered “community” based “[s]ignificant rates of marriage within 2 the group, and/or, as may be culturally required, patterned out-marriages with

3 other Indian populations[,]” the 2015 regulations permit evidence of “community” 4 through “[r]ates or patterns of known marriages within the entity, or, as may be 5 culturally required, known pattered out-marriages.” Compare 25 C.F.R. § 6 83.7(b)(1)(i) (1994) with 25 C.F.R. § 83.11(b)(1)(i) (2015). This change removes the 7 requirement that a petitioner must show evidence of patterned out-marriages with 8 other Indian populations, and consequently, allows a petitioner to present evidence

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