Case 2:25-cv-00978-APG-BNW Document 75 Filed 09/15/25 Page 2 of 20
STATEMENT OF INTEREST The Indian Gaming Association (“IGA”), California Nations Indian Gaming Association
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(“CNIGA”), Arizona Indian Gaming Association (“AIGA”), Washington Indian Gaming
Association (“WIGA”), Oklahoma Indian Gaming Association (“OIGA”), National Congress of
American Indians (“NCAI”), the Native American Finance Officers Association (“NAFOA”),
Tribal Alliance of Sovereign Indian Nations (“TASIN”), San Manuel Gaming and Hospitality
Authority (“SMGHA”), United South and Eastern Tribes Sovereignty Protection Fund (“USET
SPF”), and 24 federally recognized Indian Tribes (“Amici Tribes”) 1 (collectively, “Tribal Amici”), submit this brief as amici curiae.
As described more fully in their Motion for Leave to File Amicus Brief, the Tribal Amici
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all have a shared, strong interest in this case because of its potential to have a significant impact on
their or their member tribes’ rights regarding gaming on Indian lands, as well as Indian gaming and
tribal governmental revenue as a whole. Such revenue is vital and provides funding for essential
government services, tribal programs, and economic development needed to reach the goals of
self-governance and self-sufficiency.
ARGUMENT Indian tribes are sovereign nations with primary jurisdiction over their lands and the
activities occurring on their lands. In accordance with this principle, both the United States
Supreme Court and Congress have recognized tribes’ inherent and exclusive sovereign right to
conduct and regulate gaming on their Indian lands. California v. Cabazon Band of Mission
Indians , 480 U.S. 202 (1987); 25 U.S.C. § 2701(5). IGRA was enacted to provide a
1 The Amici Tribes include: Agua Caliente Band of Cahuilla Indians; Bay Mills Indian Community; Blue Lake Rancheria; Chicken Ranch Rancheria of Me-Wuk Indians of California; Confederated Tribes of the Grand Ronde Community of Oregon; Confederated Tribes of Siletz Indians of Oregon; Elk Valley Rancheria; Enterprise Rancheria of Maidu Indians of California; Guidiville Rancheria of California; Kickapoo Traditional Tribe of Texas; Lytton Rancheria of California; Mashantucket Pequot Indian Tribe; Morongo Band of Mission Indians; Pechanga Band of Indians; Picayune Rancheria of Chukchansi Indians; Pokagon Band of Potawatomi Indians; Pueblo of Sandia; Rincon Band of Luiseño Indians; Santa Ynez Band of Chumash Mission Indians; Seminole Tribe of Florida; Shingle Springs Band of Miwok Indians, Shingle Springs Rancheria (Verona Tract); Table Mountain Rancheria; Twenty-Nine Palms Band of Mission Indians of California; and Yuhaaviatam of San Manuel Nation.
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