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Wash. Court of Appeals published opinion — 834568 order and opinion.pdf

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Wash. Court of Appeals published opinion — 834568 order and opinion.pdf
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Washington (state)
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cannot circumvent tribal immunity through a mere pleading device.’ ” (alteration

in original) (internal quotation marks omitted) quoting Cook v. AVI Casino

Enters., Inc., 548 F. 3d 718, 726-27 (9th Cir. 2008)). And here, the activities

complained of—issuing and enforcing eviction orders—are squarely official in

their scope.

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For the current opinion, go to https://www.lexisnexis.com/clients/wareports/.
No. 83456-8-I/10

In the context of Judge Dodge’s argument about judicial immunity, the

Rabangs contend that immunity did not apply because Judge Dodge was not

properly appointed. At oral argument, the Rabangs expanded this claim by

contending that the United States Department of Interior’s (DOI) December 2016

letter “invalidated” all tribal decisions taken after March 24, 2016, and therefore

that the DOI invalidated any authority possessed by Judge Dodge or the tribal

police.6 Because these arguments could also be made in the context of

sovereign immunity—asserting that Judge Dodge and the tribal employees are

not entitled to sovereign immunity because they were not acting in an official

capacity—we address them here.

First, we cannot analyze the tribal process that was used to appoint Judge

Dodge. “In general, Indian tribes possess inherent and exclusive power over

matters of internal tribal governance.” Rabang, 328 F. Supp. 3d at 1167. We

cannot analyze if Judge Dodge was acting in his “official capacity” during the

eviction proceeding without first considering whether he was appointed

appropriately under Nooksack law. Determining whether a tribal official “had

general authority to act on behalf of the tribe in a governmental capacity [is a]

pure question[] of tribal law, beyond the purview of the federal agencies and the