Patchak v. Zinke

David Patchak sued the Secretary of the Interior, challenging the decision to take land into trust for the Match-E-Be-Nash-She-Wish Band of Pottawatomi Indians (Gun Lake Tribe) for a casino. While Patchak's case was pending, Congress enacted the Gun Lake Trust Land Reaffirmation Act, which expressly stripped federal courts of jurisdiction over lawsuits relating to that specific land. Patchak argued the Act violated the Constitution's separation of powers by directing the outcome of a pending case. The Supreme Court ruled on February 27, 2018, upholding the statute. The plurality held that Congress has broad authority to define and limit the jurisdiction of the inferior federal courts, and the Act did not invade the judicial power but merely altered the scope of jurisdiction, reaffirming congressional control over the courts' docket.

The Supreme Court reversed the D.C. Circuit and upheld the constitutionality of the Gun Lake Act. The plurality opinion, authored by Justice Thomas, concluded that the Act is a valid exercise of Congress's power to make exceptions to federal court jurisdiction and does not violate the separation of powers.

Whether the Gun Lake Trust Land Reaffirmation Act violates Article III of the Constitution by withdrawing federal court jurisdiction over a specific pending lawsuit, effectively dictating its outcome and infringing on the judicial power.

The decision reaffirmed Congress's broad authority to limit federal court jurisdiction, even for pending cases. It emboldened legislative solutions in response to adverse judicial rulings, particularly in tribal land and gaming disputes. Critics expressed concern that it allows Congress to nullify lawsuits without changing substantive law, potentially threatening judicial independence.