Upper Skagit Tribe v. Lundgren

The Upper Skagit Indian Tribe filed a quiet title action against the Lundgrens to resolve a dispute over a strip of land adjacent to the Tribe's property. The Lundgrens counterclaimed, asserting ownership of the disputed parcel. The Tribe moved to dismiss the counterclaim based on tribal sovereign immunity. The Washington Supreme Court ruled that by initiating the lawsuit, the Tribe had waived its sovereign immunity and allowed the counterclaim to proceed. On May 21, 2018, the U.S. Supreme Court reversed this decision. The Court held that the state court failed to analyze whether the disputed land constituted "Indian country" and whether the immovable property exception or other doctrines applied. The case was remanded for further proceedings consistent with the opinion.

The U.S. Supreme Court reversed the Washington Supreme Court's judgment and remanded the case. It instructed the lower court to address in the first instance whether the disputed property qualified as Indian country and to consider the application of relevant exceptions to sovereign immunity.

Whether an Indian tribe automatically waives its sovereign immunity against counterclaims in a quiet title action, and what legal test determines if the contested land falls within the scope of tribal sovereign immunity protections.

The ruling reaffirmed the robust nature of tribal sovereign immunity by rejecting the automatic waiver theory adopted by the state court. It emphasized that property disputes involving tribes require careful examination of land status under federal Indian law. The decision provided guidance for future boundary and title disputes, reinforcing the sovereignty of Native American tribes while acknowledging the complexities of adjoining landowner conflicts.