Madison County v. Oneida Indian Nation of N.Y.

Summary

The Supreme Court vacated the Second Circuit's judgment and remanded the case for consideration of whether a newly enacted Oneida Indian Nation waiver of sovereign immunity affected the court's prior ruling. The Court directed the Second Circuit to address other issues, including the status of the Oneida reservation, if necessary, and awarded petitioners costs.

Holdings

1. The Second Circuit must address in the first instance whether to revisit its sovereign-immunity ruling in light of the Oneida Nation's newly adopted waiver.
2. If necessary after reconsidering sovereign immunity, the Second Circuit should address the other questions in the case consistently with its sovereign-immunity ruling.

Questions Presented

1. Whether the Oneida Indian Nation's newly adopted waiver of sovereign immunity required the Second Circuit to reconsider its ruling that tribal sovereign immunity barred foreclosure proceedings to collect lawfully imposed property taxes.
2. Whether the status of the ancient Oneida reservation had to be addressed after reconsideration of the sovereign-immunity issue.

Disposition

vacated