Dollar General Corp. v. Mississippi Band of Choctaw Indians facts for kids
Quick facts for kids Dollar General Corp. v. Mississippi Band of Choctaw Indians |
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| Argued Dec. 7, 2015 Decided June 23, 2016 |
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| Full case name | Dollar General Corp. and Dolgencorp LLC v. the Mississippi Band of Choctaw Indians; the Tribal Court of the Mississippi Band of Choctaw Indians; Christopher A. Collins, in his Official Capacity; John Doe, a minor, by and through his parents and next friends, John Doe, Sr. and Jane Doe |
| Docket nos. | 13-1496 |
| Citations | 579 U.S. ____ (more)
136 S. Ct. 2159; 195 L. Ed. 2d 637
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| Prior history | Dolgencorp, Inc. v. Mississippi Band of Choctaw Indians, 846 F. Supp. 2d 646 (S.D. Miss. 2011); affirmed, 746 F.3d 167 (5th Cir. 2014); cert. granted, 135 S. Ct. 2833 (2015). |
| Argument | Oral argument |
| Opinion Announcement | Opinion announcement |
| Holding | |
| Affirmed by an equally divided Court | |
| Court membership | |
| Case opinions | |
| Per curiam. | |
Dollar General Corp. v. Mississippi Band of Choctaw Indians was a case heard by the Supreme Court of the United States. It happened in 2016. The Court had to decide if a Native American tribal court could handle a civil lawsuit. This lawsuit involved a non-Native American person. This person ran a Dollar General store on land belonging to the tribe.
The Supreme Court ended up with a 4–4 tie vote. Because of the tie, the decision of the lower court was upheld. This meant the tribal court did have the power to hear the case.
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What Happened in the Case?
The Mississippi Band of Choctaw Indians is a Native American tribe. They have several communities in Mississippi. Their land is held in trust by the U.S. Government. This means the government manages the land for the tribe's benefit.
Since 2000, Dollar General has rented space from the tribe. They operate a store on tribal land. They also got a business license from the tribe.
In 2003, a 13-year-old tribal member, called John Doe in court papers, was working at the store. He was part of a special internship program. This program was a partnership between the tribe and Dollar General. John Doe later said that the store manager caused him "severe mental trauma."
The tribe took action to keep the manager off their lands. However, the U.S. government did not bring criminal charges against him.
Lawsuit in Tribal Court
In 2005, John Doe sued the store manager and Dollar General. He filed the lawsuit in the tribal court. The lawsuit asked for money to cover damages.
The defendants, Dollar General and the manager, tried to get the case thrown out. They argued that the tribal court did not have the power to hear cases involving non-Native Americans.
The tribal court disagreed and decided to keep the lawsuit. The Choctaw Supreme Court supported this decision. They pointed to an earlier Supreme Court case, Montana v. United States. This case said that tribes could handle civil cases involving non-Native Americans on tribal land. This is allowed if the non-Native Americans had a voluntary relationship with the tribe.
Case Moves to Federal Court
After this, the store manager and Dollar General sued the Tribe. They did this in a federal court, the United States District Court for the Southern District of Mississippi. They wanted to stop the lawsuit in the tribal court.
The district court removed the manager from the case. But it decided that Dollar General had a voluntary relationship with the tribe. So, Dollar General was subject to the tribal court's power.
Appeal to the Fifth Circuit
Dollar General then appealed this decision. They went to the United States Court of Appeals for the Fifth Circuit. This court also agreed with the lower court.
A panel of three judges heard the case. Judge James E. Graves Jr. wrote the court's opinion. He found that the situation fit the rules from the Montana case. This meant the tribal court could indeed handle the case against Dollar General.
The Supreme Court's Decision
Dollar General then appealed to the U.S. Supreme Court. They asked the Court to decide if tribal courts could hear civil cases against non-Native Americans. This was specifically about cases where the non-Native American had a voluntary relationship with the tribe.
Arguments Made to the Court
Dollar General argued that tribes no longer had the power to judge cases involving non-Native Americans. They said that only Congress or a clear agreement from the non-Native American could give tribes this power. Dollar General wanted the Court to make a similar rule for civil cases as it did for criminal cases in Oliphant v. Suquamish Indian Tribe.
The Choctaw tribe argued that they had their own power as a tribe. They said this power would only be taken away if Congress clearly stated so. The tribe felt that the Montana case had already settled this issue. They believed the only question was whether Dollar General had agreed to be part of the tribal system.
The Solicitor General of the United States, who represents the U.S. government in court, supported the Choctaw tribe. He asked the Court not to take the case. He also said that the Fifth Circuit's decision was correct.
The Court's Opinion
The Supreme Court announced its decision on June 23, 2016. The decision was a per curiam opinion. This means it was a decision from the entire Court, not written by one specific justice.
Chief Justice John Roberts announced the decision. The opinion simply stated: "The judgment is affirmed by an equally divided Court."
This happened because Justice Antonin Scalia had passed away in February. This left the Court with only eight members. When the Court has an even number of justices and they tie, the decision of the lower court stands. However, a tie vote does not create a new legal rule for future cases. It's as if the Supreme Court never heard the case for legal precedent.
