Chelsea Farrer and Chad Young v. Waneka Rosebud Cornpeach

Summary

The United States District Court for the District of Utah held that it lacked federal-question jurisdiction over Plaintiffs’ Utah-law tort claims against a tribal officer and remanded the action to Utah state court under 28 U.S.C. § 1447(c). The court denied the motion for declaratory judgment as moot, concluding that anticipated defenses involving tribal sovereignty, the infringement doctrine, or tribal immunity did not satisfy the well-pleaded complaint rule.

Holdings

1. A defendant's reliance on the tribal infringement doctrine, tribal sovereignty, or a related federal immunity or jurisdictional defense does not create federal-question jurisdiction under § 1331 when the plaintiff's well-pleaded complaint asserts only state-law claims and does not present a federal question.
2. The action had to be remanded to Utah state court because the district court was not satisfied that subject matter jurisdiction existed.
3. Defendant's motion for a declaratory judgment concerning the state court's jurisdiction was denied as moot after the federal action was remanded.

Questions Presented

1. Whether federal-question jurisdiction under 28 U.S.C. § 1331 existed when plaintiffs' well-pleaded complaint asserted only state-law tort claims and defendant relied on the tribal infringement doctrine and related tribal-sovereignty defenses.
2. Whether the district court was required to remand the removed action under 28 U.S.C. § 1447(c) for lack of subject matter jurisdiction.
3. Whether defendant's motion for a declaratory judgment concerning the state court's jurisdiction could be decided after the federal court determined that it lacked subject matter jurisdiction.

Disposition

remanded