Salt River Project Agricultural Improvement and Power Dist., et al. v. Lee, et al.

Two non-Indian entities brought this action to enjoin Navajo Nation tribal officials from applying tribal law to them in tribal courts. They claimed that both their contract with the tribe and federal law deprived tribal officials of authority to regulate them. At issue was whether the Navajo Nation itself was a necessary party under Rule 19. The court held that the tribe was not a necessary party because the tribal officials could be expected to adequately represent the tribe's interests in this action and because complete relief could be accorded among the existing parties without the tribe. Thus, this lawsuit for prospective injunctive relief could proceed against the officials under a routine application of Ex parte Young and should not be dismissed. View "Salt River Project Agricultural Improvement and Power Dist., et al. v. Lee, et al." on Justia Law