8/10/22
Pre-IGRA Gaming
A number of tribal governments, including the Seminole, Eastern Band of Cherokee, and the Cabazon Tribe, among others, introduced high stakes bingo, which proved highly popular and lucrative In June 1984, the Interior Department presented testimony to Congress noting that 80 tribes were engaged in some form of gaming, primarily bingo, and the income from those operations was, in total, in the millions of dollars Bingo in Indian Country proved so successful in such a short time that state governments took notice States began taking the position that bingo games were illegal under state law
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The Supreme Court’s decision in California v. Cabazon and Morongo Bands of Mission Indians (1987) paved the way for the Indian Gaming Regulatory Act (IGRA), passed the following year. In Cabazon , the State of California argued that under Public Law 280, California had criminal jurisdiction over tribal lands within the state’s borders. The Cabazon and Morongo Bands argued that the state’s regulatory laws did not criminally prohibit gambling; therefore, the authority to regulate such gaming activities was outside the control of Public Law 280. The Supreme Court agreed with the tribes and ruled against California having authority to regulate or prohibit tribal gaming. Cabazon prompted Congress to adopt a federal regulatory framework for Indian gaming.
Setting the Stage in Court
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