State of RI v. Narragansett Tribe

Case Date: 03/25/1994
Court: United States Court of Appeals
Docket No: 93-1400



UNITED STATES COURT OF APPEALS
FOR THE FIRST CIRCUIT

_________________________

No. 93-1400

STATE OF RHODE ISLAND, ET AL.,
Plaintiffs, Appellants,

v.

NARRAGANSETT INDIAN TRIBE, ET AL.,
Defendants, Appellees.

_________________________

APPEAL FROM THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF RHODE ISLAND

[Hon. Raymond J. Pettine, Senior U.S. District Judge] __________________________

_________________________

Before

Selya, Circuit Judge, _____________

Aldrich and Coffin, Senior Circuit Judges. _____________________

_________________________

W. Mark Russo, with whom Jeffrey B. Pine, Attorney General, _____________ _______________
Alan M. Shoer, Special Assistant Attorney General, Elizabeth ______________ _________
Murdock Myers, Suzanne Worrell, and Adler, Pollock & Sheehan were _____________ _______________ ________________________
on brief, for state appellants.
Bruce N. Goodsell on brief for municipal appellants. _________________
Scott Harshbarger, Attorney General (Mass.), Douglas H. __________________ __________
Wilkins, Assistant Attorney General (Mass.), Michael J. _______ ___________
Carpenter, Attorney General (Me.), and Frankie Sue Del Papa, _________ ______________________
Attorney General (Nev.) on brief for States of Massachusetts,
Maine, and Nevada, amici curiae.
Charles A. Hobbs, with whom Arlene Violet, Matthew S. Jaffe, ________________ _____________ ________________
and Hobbs, Straus, Dean & Wilder were on brief, for appellees. ____________________________

_________________________

March 23, 1994

_________________________



SELYA, Circuit Judge. This appeal requires us to SELYA, Circuit Judge. ______________

determine whether the Indian Gaming Regulatory Act, 25 U.S.C.

2701-2721, 18 U.S.C. 1166-1168 (1988) (the Gaming Act),

applies to lands now held in trust by the United States for the

benefit of the Narragansett Indian Tribe (the Tribe). This

determination is tinged with more than the usual quotient of

public interest, because the Tribe's ability to import casino

gambling into Rhode Island likely hangs in the balance. After

careful reconnaissance of a littered legal landscape, we set

aside the district court's determination that the parties'

dispute over the applicability of state jurisdiction is not yet

ripe for adjudication and hold that Congress's grant of

jurisdiction to the state in the Rhode Island Indian Claims

Settlement Act of 1978, 25 U.S.C. 1701-1716 (the Settlement

Act), remains valid. We also hold, contrary to the Tribe's

importuning, that the grant includes civil regulatory

jurisdiction.

At that juncture, the tide turns. We conclude, despite

the state's vehement protests, that the Gaming Act does not

specially exempt the lands in question; that the Narragansetts

have concurrent jurisdiction over, and exercise governmental

power with respect to, those lands, and, therefore, are entitled

to invoke the Gaming Act; and that, to the extent of the

jurisdictional conflict between the Settlement Act and the Gaming

Act, the former is impliedly repealed. In the end, we affirm

both the district court's directive that Rhode Island enter into
2


good faith negotiations to draft a tribal-state compact under

which gaming operations can be mounted and its refusal to grant

relief to various governmental figures and entities who have

challenged the Tribe's entitlement to the extraordinary

prophylaxis of the Gaming Act.

I. THE SETTLEMENT LANDS I. THE SETTLEMENT LANDS

We begin with a thumbnail sketch of how the land mass

that is the breeding ground for this dispute came to be held in

trust for the Tribe.

In the late 1970s, the Tribe asserted title claims to

certain lands in Charlestown, Rhode Island, and, encountering

resistance, pursued these claims in the federal courts. See Town ___ ____

of Charlestown v. United States, 696 F. Supp. 800, 801-05 (D.R.I. ______________ _____________

1988) (recounting history of dispute), aff'd, 873 F.2d 1433 (1st _____

Cir. 1989) (table). In 1978, the Tribe, the state, and the Town

of Charlestown signed a joint memorandum of understanding (J-MEM)

purporting to settle their differences. The Tribe agreed, inter _____

alia, to the extinguishment of its title claims. In return, it ____

obtained valuable consideration, including a lump-sum payment and

effective control over roughly 1800 acres in Charlestown (the

settlement lands), half donated by the state and half by private

landowners.1 The titleholders agreed to deed the property to a

____________________

1The provenance of the two parcels remains of continuing
legal relevance because the 900 acres donated by the state may be
used only for conservation purposes. See 6A R.I. Gen. Laws 37- ___
18-14 (1990). Thus, the development plan for high-stakes
gambling is of necessity limited to the so-called "private"
portion of the settlement lands.

3


nascent corporation which would be formed to hold title for the

Tribe's benefit.

Because Congress possesses plenary power over Indian

matters, see Morton v. Mancari, 417 U.S. 535, 551-52 (1974), the ___ ______ _______

parties sought its blessing. In response, Congress passed the

Settlement Act, a law that, for the most part, tracks the J-MEM.

In 1978, the state legislature approved the Narragansett Indian

Land Management Corporation Act, 6A R.I. Gen. Laws 37-18-1 to

37-18-15 (1990) (the State Act), thereby creating the nominee

corporation that would hold title to the settlement lands. The

necessary conveyancing followed.

The next five years passed without relevant incident.

Then, in 1983, the Secretary of the Interior, acting pursuant to

departmental regulations, see 25 C.F.R., Part 83 (1993), ___

officially recognized the Narragansetts as an Indian tribe. See ___

48 Fed. Reg. 6177-78 (Feb. 2, 1983). On the heels of federal

recognition, the settlement lands changed hands twice more. In

1985, the Rhode Island General Assembly amended the State Act to

permit the holding company to transfer title to the Tribe.2 The

corporation complied. In September of 1988, less than a month
____________________

2The State Act amendments themselves suggest that
congressional approval of the land transfer is "required and
appropriate," 6A R.I. Gen. Laws 37-18-14, and the case law is
in accord, see Oneida Indian Nation v. Oneida County, 414 U.S. ___ _____________________ ______________
661, 667-68 (1974) (explaining that, as a general rule, Indian
tribes may not alienate their land without congressional
consent). Yet, Congress never ratified the State Act amendments.
Because the validity of the title transfer is not directly in
issue in this litigation, and because appellants have not
acknowledged, much less relied upon, the absence of ratification,
we do not explore the consequences of this omission.

4


before the Gaming Act became law, the Tribe deeded the settlement

lands to the federal Bureau of Indian Affairs (the Bureau) as

trustee.

II. THE GAMING ACT II. THE GAMING ACT

The Gaming Act is an expression of Congress's will in

respect to the incidence of gambling activities on Indian lands.

The statute sets in place a sophisticated regulatory framework,

defining a species of gambling, called "gaming," and dividing it

into tiers, called "classes." Each class connotes a different

level of gambling activity and, consequently, each class is

regulated to a varying degree of stringency. See 25 U.S.C. ___

2703(6) - 2703(8).

Class I gaming which consists, essentially, of Indian

ritual gambling always can be conducted on Indian lands. See ___

25 U.S.C. 2710(a)(1). Class II gaming which encompasses

bingo can be conducted as of right on Indian lands in any

state, such as Rhode Island, that does not generally proscribe

activities of that type. See 25 U.S.C. 2710(b)(1)(A). Class ___

III gaming a residual category that includes what is commonly

thought of as casino gambling is permitted by compact; and,

moreover, a state is obliged to negotiate such a compact in good

faith with a sponsoring tribe unless the state bans all persons

throughout its territory from conducting class III gaming. See ___

25 U.S.C. 2710(d). Short of an outright ban and few state
5


legislatures have indicated a willingness to go that far3 the

tribal-state compact is the exclusive method of regulating class

III gaming. The method of the Gaming Act prevents a state from

frustrating the introduction of class III gaming by an endless

filibuster, for there are tight time parameters within which

compact negotiations must be brought to fruition once a federal

court finds that a state has failed to bargain in good faith.

See id. 2710(d)(7)(B). As a practical matter, then, a state ___ ___

ordinarily may regulate casino gambling on Indian lands only in

pursuance of a consensual compact.

Because the case at bar revolves around class III

gaming, the centrality of this last point cannot be

overstated. One of the Gaming Act's fundamental policies is that

"Indian tribes have the exclusive right to regulate gaming

activity on Indian lands . . . ." Id. 2701(5). The ___

legislative history of the statute draws out the implications of

this policy:

The mechanism for facilitating the unusual
relationship in which a tribe might
affirmatively seek the extension of State
jurisdiction and the application of state
laws to activities conducted on Indian land
is a tribal-State compact. In no instance
does [the Gaming Act] contemplate the
extension of State jurisdiction or the
application of State laws for any other
purpose.

____________________

3There are strong economic and political disincentives to an
outright ban, for class III gaming encompasses, among other
things, such popular sources of state revenue as lotteries, and
such familiar fundraising devices as "Las Vegas nights" to
benefit churches and other charities.

6


S. Rep. No. 446, 100th Cong., 2d Sess. 3, reprinted in 1988 _________ __

U.S.C.C.A.N. 3071, 3075-76.

Under our tripartite system of government, Congress,

not the courts, is empowered to make such policy choices. See ___

Irons v. FBI, 811 F.2d 681, 689 (1st Cir. 1987) (acknowledging _____ ___

that the legislative branch sets policy by means of statutes and

the courts must honor the legislature's policy choices and

enforce the statutes). Thus, the courts have not focused on the

wisdom of the policies underlying the Gaming Act, but have

followed the legislative lead and recognized that the very

structure of the Gaming Act forbids the assertion of state civil

or criminal jurisdiction over class III gaming except when the

tribe and the state have negotiated a compact that permits state

intervention. See, e.g., United Keetoowah Band of Cherokee ___ ____ ____________________________________

Indians v. Oklahoma, 927 F.2d 1170, 1177 (10th Cir. 1991); Sycuan _______ ________ ______

Band of Mission Indians v. Roache, 788 F. Supp. 1498, 1504 (S.D. _______________________ ______

Cal. 1992).

III. PROCEEDINGS BELOW III. PROCEEDINGS BELOW

On January 15, 1992, the Tribe formally requested that

Rhode Island enter into good faith bargaining designed to produce

a tribal-state compact that would allow construction and

operation of a casino, i.e., inauguration of class III gaming, on ____

the settlement lands. Rhode Island declined to negotiate,

instead filing suit in the federal district court.4 The state
____________________

4As matters now stand, the named plaintiffs (appellants
before us) include the state, the town, and various state and
municipal officials. For simplicity's sake, we refer to the

7


asked the court to declare that the Gaming Act does not apply to

the settlement lands, and that, therefore, those lands are

subject to Rhode Island's general criminal and civil laws

(including its civil regulatory laws). The state also sought to

enjoin the development of gambling facilities on the settlement

lands and to block negotiations antecedent to a tribal-state

compact. The Tribe answered and counterclaimed for declaratory

and injunctive relief that would pave the way for casino gambling

on the settlement lands. The tribe requested, among other

things, a declaration that the state's civil regulatory laws do

not apply to the settlement lands; a declaration that the

Narragansetts are entitled to operate a class III casino on those

lands in conformance with the Gaming Act; and a mandatory

injunction commanding the state to negotiate in good faith toward

a compact.

The district court considered cross motions for summary

judgment premised on a joint statement of uncontroverted facts.

After pondering the parties' proffers, the court deferred

substantive consideration of the dispute over the general

applicability of state and local jurisdiction, citing ripeness

concerns. See Rhode Island v. Narragansett Tribe of Indians, 816 ___ ____________ _____________________________

F. Supp. 796, 799-800 (D.R.I. 1993). The court then assumed, for

argument's sake, that the state had been granted jurisdiction

____________________

plaintiffs, collectively, as "Rhode Island" or "the state."
Similarly, we refer to the defendants, collectively, as "the
Narragansetts" or "the Tribe," noting, however, that plaintiffs'
suit also names two tribal hierarchs as defendants.

8


over the settlement lands by virtue of the Settlement Act. See ___

id. at 804. Proceeding on that assumption, the court concluded ___

that any such grant was "preempted" by the Gaming Act, and,

consequently, had no enduring force or effect. Id. Based on ___

these findings, the court ordered the state to enter into good

faith negotiations to formulate a tribal-state compact. See id. ___ ___

at 806.

In reaching the conclusion that the Gaming Act

controlled, the court divided its reasoning into four parts.

First, it cited with approval three precedents holding that the

Gaming Act overrode other federal statutes of earlier vintage.

See id. at 801-02. Second, it found the evidence of Congress's ___ ___

intent to place Rhode Island beyond the Gaming Act's sphere to be

unpersuasive in the absence of textual support in the statute.

See id. at 802-04. Third, it dismissed the suggestion that the ___ ___

Gaming Act could not trump the Settlement Act because the former

was the more general of the two statutory schemes. See id. at ___ ___

804. Fourth, it determined that the Tribe "ha[d] jurisdiction"

and "exercise[d] governmental power" over the settlement lands in

sufficient measure to animate the Gaming Act. See id. at 805-06. ___ ___

After the plaintiffs filed a timely notice of appeal,

the district court stayed its order.5

IV. THE DECISIONAL FRAMEWORK IV. THE DECISIONAL FRAMEWORK

____________________

5The Tribe originally cross-appealed from the stay and from
the denial of its motion for relief therefrom. In a separate
order, we today dismiss that cross-appeal, the Tribe having
failed to present any developed argumentation in support thereof.

9


The search for statutory meaning inevitably reduces to

a pure question of law. Thus, the issues on appeal engender de __

novo review, to be conducted without special deference to the ____

district court's views. See, e.g., FDIC v. Keating, ___ F.3d ___ ____ ____ _______

___, ___ (1st Cir. 1993) (per curiam) [No. 93-1230, slip op. at

4]; Liberty Mut. Ins. Co. v. Commercial Union Ins. Co., 978 F.2d _____________________ __________________________

750, 757 (1st Cir. 1992). When a court interprets statutes that

touch on Indian sovereignty, general rules of construction apply,

but they must be visualized from a distinctive perspective. The

Court has described this coign of vantage:

The underlying premise is that congressional
intent will control. In determining this
intent, we are cautioned to follow "the
general rule that `[d]oubtful expressions are
to be resolved in favor of [Indians]". . . .
But the "general rule" does not command a
determination . . . in the face of
congressionally manifested intent to the
contrary. In all cases, "the face of the
Act," the "surrounding circumstances," and
the "legislative history," are to be examined
with an eye toward determining what
congressional intent was.

Rosebud Sioux Tribe v. Kneip, 430 U.S. 584, 586-87 (1977) _____________________ _____

(citations omitted); see also South Carolina v. Catawba Indian ___ ____ ______________ ______________

Band, 476 U.S. 498, 506 & n.16 (1986) (collecting cases). ____

Our search follows an odd trajectory in this case,

because it starts down a road that the district court chose not

to explore, and, once that journey is ended, proceeds to trace

the path of an argument that ultimately proves to be a dead end.

Although this approach is unorthodox, we think it facilitates a

systematic testing of the appellants' core contention: that the
10


settlement lands lie beyond the Gaming Act's reach.

The nature of our approach makes it desirable that we

set out a roadmap. We propose, in the following two parts, to

deal with the Settlement Act, for, if that statute did not confer

state jurisdiction in respect to the settlement lands, or if

state jurisdiction, once conferred, vanished before the Gaming

Act materialized, then the state's case would necessarily

founder. To this end, we discuss in Part V whether the

jurisdictional inquiry is ripe; finding that it is, we discuss in

Part VI the validity and scope of the jurisdiction ceded to the

state by the Settlement Act.

Next, we must consider the Gaming Act's effect on the

state's jurisdiction. In Part VII, we deal with and rebuff

the state's suggestion that the settlement lands are entirely

exempt from the Gaming Act. In Part VIII, we deal with and

rebuff the state's argument that, even absent a categorical

exemption, the Tribe's relationship to the settlement lands does

not possess the attributes needed to trigger the Gaming Act's

provisions. The final curtain falls at the conclusion of Part

IX, where we confront the interface between the Settlement Act

and the Gaming Act, and test the district court's remedial order

in the crucible of our understanding.

V. RIPENESS V. RIPENESS

The lower court declined to resolve the issue of state

and local jurisdiction, finding no "case of actual controversy"

sufficient to satisfy the Declaratory Judgment Act, 28 U.S.C.
11


2201 (1988). Narragansett Tribe, 816 F. Supp at 800. Though we __________________

are mindful of the deference due to a district court's decision

to withhold a grant of declaratory relief, see El Dia, Inc. v. ___ ____________

Hernandez Colon, 963 F.2d 488, 492 (1st Cir. 1992), we believe ________________

that the court abused its discretion in this instance.

A. The Applicable Standards. A. The Applicable Standards. ________________________

When faced with questions of ripeness in the

declaratory judgment context, this court employs the test

developed in Abbott Laboratories v. Gardner, 387 U.S. 136, 149 ___________________ _______

(1967). The test, as phrased in our cases, contains two parts:

First, we consider whether an issue is fit
for review, e.g., whether a challenged
government action is final and whether
determination of the merits turns upon facts
which may not yet be sufficiently developed.
Second, we consider the question of hardship,
a question which typically turns upon whether
the challenged action creates a direct and
immediate dilemma for the parties.

El Dia, 963 F.2d at 495 (citation and internal quotation marks _______

omitted); accord W.R. Grace & Co. v. United States EPA, 959 F.2d ______ ________________ __________________

360, 364 (1st Cir. 1992). The key consideration in this analysis

"is the extent to which the claim involves uncertain and

contingent events that may not occur as anticipated, or indeed

may not occur at all." Lincoln House, Inc. v. Dupre, 903 F.2d ___________________ _____

845, 847 (1st Cir. 1990) (citation and internal quotation marks

omitted).

Applying this test in the declaratory judgment context

often requires custom tailoring, for there are at least two

salient differences between declaratory actions and the mine-run
12


of other cases: first, declaratory relief is more likely to be

discretionary; and, second, declaratory actions contemplate an

"ex ante determination of rights" that "exists in some tension _______

with traditional notions of ripeness." Step-Saver Data Systems, ________________________

Inc. v. Wyse Technology, 912 F.2d 643, 647 (3d Cir. 1990). Our ____ _______________

opinion in El Dia responded to the first of these differences. ______

See El Dia, 963 F.2d at 491-93. We believe that our opinion ___ ______

today responds to the second difference.

The linchpin of ripeness under the Declaratory Judgment

Act, as in all Article III cases, is adverseness. In a

declaratory judgment action adverseness must be appraised in a

practical, commonsense way. Thus, satisfying the adverseness

requirement demands that "the facts alleged, under all the

circumstances, show that there is a substantial controversy,

between parties having adverse legal interests, of sufficient

immediacy and reality to warrant the issuance of a declaratory

judgment." Maryland Casualty Co. v. Pacific Coal & Oil Co., 312 _____________________ _______________________

U.S. 270, 273 (1941), citing Aetna Life Ins. Co. v. Haworth, 300 ___________________ _______

U.S. 227, 239-42 (1937). This requirement should not be applied

woodenly. Most litigation has idiosyncratic features, and the

adverseness criterion invites careful calibration on a case-by-

case basis. The line is often difficult to draw. While a

declaratory judgment should not be granted "in speculative

situations," Public Affairs Assocs., Inc. v. Rickover, 369 U.S. _____________________________ ________

111, 112 (1962), a litigant "does not have to await the

consummation of threatened injury to obtain preventive relief.
13


If the injury is certainly impending that is enough." Pacific _______

Gas & Elec. Co. v. State Energy Resources Conserv. & Dev't _________________ ___________________________________________

Comm'n, 461 U.S. 190, 201 (1983) (citation omitted). ______

One sound way of gauging adverseness is to evaluate the

nature of the relief requested. The controversy must be such

that it admits of "specific relief through a decree of conclusive

character, as distinguished from an opinion advising what the law

would be upon a hypothetical state of facts." Aetna Life, 300 ___________

U.S. at 240-41. Some courts call this measure of adverseness

"conclusivity" and treat it as a separate requirement. See, ___

e.g., Armstrong World Indus., Inc. v. Adams, 961 F.2d 405, 421-23 ____ ____________________________ _____

(3d Cir. 1992).

The second part of the ripeness inquiry evoked by

declaratory judgment actions is concerned with the hardship to

the parties that would result from a refusal to consider granting

relief. We believe that this part of the inquiry should focus on

the judgment's usefulness. Rather than asking, negatively,

whether denying relief would impose hardship, courts will do well

to ask, in a more positive vein, whether granting relief would

serve a useful purpose, or, put another way, whether the sought-

after declaration would be of practical assistance in setting the

underlying controversy to rest. See Step-Saver, 912 F.2d at 647. ___ __________

This formulation is hardly a radical departure from

Abbott Laboratories and its progeny, for the one question may ____________________

always be transformed into the other. For example, to say that

denying relief is tolerable where an adequate state remedy has
14


been realized is tantamount to saying that granting the requested

relief in such a situation would be pointless. See El Dia, 963 ___ _______

F.2d at 495. Indeed, the Court some time ago observed that one

reason the legal issues must be crystallized in a declaratory

action is to enable the trial judge to see "some useful purpose

to be achieved in deciding them." Public Service Comm'n v. ______________________

Wycoff Co., 344 U.S. 237, 244 (1952). Furthermore, framing the __________

hardship question in a positive fashion best comports with the

spirit of the Declaratory Judgment Act. As Judge Becker

explained: "The idea behind the Act was to clarify legal

relationships so that plaintiffs (and possibly defendants) could

make responsible decisions about the future." Step-Saver, 912 __________

F.2d at 649 (citing legislative history).

B. Applying the Standards. B. Applying the Standards. ______________________

Here, the district court's ruling on ripeness flowed

from the notion that neither the state nor the town would have

any occasion to exercise reserved jurisdiction until the compact

negotiation process ended, thereby clearing the way for class III

gaming. Narragansett Tribe, 816 F. Supp. at 799-800. The court __________________

seemed to focus on the uncertainty of the situation, suggesting

that the need for the relief requested depended on the occurrence

of speculative events. We disagree.

Whether state and local authorities retain any ___

jurisdiction over the settlement lands is a question of immediate

importance to all parties, separate and apart from the question

of precisely what state and local jurisdiction survives. We
15


think, in fairness to the parties, that the former question must

be settled before they are ordered to commence negotiations for a

tribal-state compact. Because the required interpretation of the

Settlement Act projects a "purely legal" issue, W.R. Grace, 959 __________

F.2d at 364, the resolution of which will not be changed by

further factual development, and because it is of critical

importance to the negotiation process in which the parties must

engage, see infra Part IX(B), the case for a finding of ___ _____

adverseness is very powerful. And, moreover, while it is true

that the compact negotiations may bear on the timing of class III

gaming and the allocation of regulatory responsibilities, the

negotiations cannot effect the existence vel non of state and ___ ___

local jurisdiction.

The impetus for reaching the merits is strengthened

because the other characteristics traditionally associated with

ripeness are also extant. We have no serious reservation about

whether the proper parties are before the court or whether the

requested ruling will, if granted, conclusively define the

parties' baseline legal rights. By like token, such a ruling

would be of great near-term utility, facilitating the course of

future tribal-state compact negotiations and clarifying to some

extent the legal status of the settlement lands at a time when

substantially expanded use seems highly probable. Accordingly,

we rule that the basic issue of state and local jurisdiction

(although not the specific, fact-intensive permutations of that

issue, see infra Part IX(C)) is ripe for declaratory judgment ___ _____
16


purposes.

VI. STATE AND LOCAL JURISDICTION VI. STATE AND LOCAL JURISDICTION

Addressing the merits of this issue entails an

examination of the validity and scope of the Settlement Act. The

Act states that, with two exceptions not relevant here,6 "the

settlement lands shall be subject to the civil and criminal laws

and jurisdiction of the State of Rhode Island." 25 U.S.C.

1708. The Tribe maintains that this pronouncement was nugatory

when made, or, if initially effective, was relegated to the scrap

heap well before Congress enacted the Gaming Act. The Tribe also

maintains that, validity aside, any grant of jurisdiction

excludes civil regulatory jurisdiction, and, therefore, has no

bearing upon the proposed operation of a gambling casino. We are

not persuaded.

A. Validity. A. Validity. ________

The Tribe's basic position is that, even prior to the

Gaming Act, section 1708 of the Settlement Act did not constitute

a valid conferral of jurisdiction because, until federal

recognition occurred in 1983, the Tribe had no jurisdiction to

relinquish.

This resupinate reasoning stands logic on its ear. The

Tribe did not surrender jurisdiction in 1978. Rather, the Tribe, _________

the state, and the town came to an agreement, spelled out in the

J-MEM, to ask Congress, among other things, to grant jurisdiction
____________________

6The exceptions relate to the Tribe's general exemption from
state taxation, 25 U.S.C. 1715(a), and its exemption from state
regulations anent fishing and hunting, 25 U.S.C. 1706(a)(3).

17


to the state. The Tribe has articulated no reason why,

regardless of its legal status, Congress lacked the power to

effectuate this jurisdictional grant.

In any event, the Tribe is mistaken in its professed

belief that it lacked jurisdictional power at the time of the

Settlement Act. Federal recognition is just that: recognition

of a previously existing status. The purpose of the procedure is

to "acknowledg[e] that certain American Indian tribes exist." 25

C.F.R. 83.2 (1993). The Tribe's retained sovereignty predates

federal recognition indeed, it predates the birth of the

Republic, see Santa Clara Pueblo v. Martinez, 436 U.S. 49, 56 ___ ___________________ ________

(1978) and it may be altered only by an act of Congress, see ___

Morton, 417 U.S. at 551-52.7 ______

The Tribe has two other arrows in its jurisdictional

quiver. First, it hypothesizes that section 1708 did not survive

federal recognition. This hypothesis is the mirror image of the

hypothesis just considered: rather than being cast as the

prerequisite for the conferral of jurisdiction, recognition is

taken to have nullified that conferral. The two hypotheses

suffer from the same infirmity. Tribal sovereignty (and, hence,

jurisdiction) may be neither augmented nor diminished except
____________________

7This legal principle also disposes of certain other
arguments raised by the Tribe. Thus, the Tribe's sovereignty
could not have been eviscerated by an act of the Rhode Island
General Assembly, unratified by Congress, that purported to
extinguish tribal status, see 1879-1880 Acts, Resolves and ___ ____________________
Reports of the General Assembly of the State of Rhode Island and _________________________________________________________________
Providence Plantations, Chap. 800, at 101-06, or by the issuance ______________________
of mere administrative notices, see, e.g., 48 Fed. Reg. 6177-78 ___ ____
(Feb. 2, 1983).

18


through congressional enactment. Second, the Tribe suggests

that, if section 1708 survived recognition, it did not survive

the subsequent alienation of the settlement lands. This

suggestion goes nowhere. Supposing that the jurisdictional grant

contained in section 1708 could have been jettisoned by the

state, the Tribe, or the Bureau without congressional sanction

a supposition we do not share the fact is that, at every

salient moment, the parties in interest took pains to reaffirm

section 1708.8 We conclude, therefore, that the grant of

jurisdiction contained in section 1708 of the Settlement Act was

valid when made, and was undiluted at the time Congress passed

the Gaming Act.

B. Scope. B. Scope. _____

Validity notwithstanding, it is an open question

whether the jurisdictional grant contained in section 1708

extends to civil regulatory jurisdiction. The Tribe insists not.

It tells us that the enacting Congress intended to copy the

distinction between civil regulatory and civil adjudicatory

jurisdiction limned two years earlier in Bryan v. Itasca County, _____ ______________

426 U.S. 373 (1976). We find this tale to be both unsupported

and unsupportable.

The Tribe's argument runs along the following lines.

____________________

8The 1985 State Act amendments transferring title from the
holding company to the Tribe contained a provision for state
jurisdiction substantially identical to that contained in section
1708, see 6A R.I. Gen. Laws 37-18-13(b); and the deeds ___
conveying the settlement lands from the Tribe to the Bureau in
1988 explicitly confirmed the applicability of section 1708.

19


In its view, there are salient discrepancies in respect to

jurisdiction among the J-MEM, the original Senate bill leading to

the Settlement Act, and the final version of the Act itself. To

illustrate the Tribe's point, we list the three versions of the

jurisdictional clause side by side, in order of drafting.

According to three documents, the settlement lands were to be

subject to:

All laws of the state . . . including but not
limited to state and local building, fire and
safety codes [J-MEM, 13];

the complete civil and criminal jurisdiction
of the State. . . . [Joint Hearing on S.3153
and H.R. 12860, 95th Cong., 2d Sess., at 36,
51 (June 20, 1978)];

the civil and criminal laws and jurisdiction
of the State. . . . [18 U.S.C. 1708].

Analogizing to Bryan, the Tribe posits that this progression _____

signals Congress's intent to limit the jurisdictional grant.

This proposed interpretation finds no succor in the

legislative history. Without such support, we think it is

evident that the Narragansetts read too much into too little.

Considering the overall context, the deviations from one document

to another do not strike us as especially significant. The

progressive development of the jurisdictional language can more

plausibly be interpreted as intended to clarify the breadth of

the grant, rather than to narrow it. Perhaps the drafters feared

that "all laws of the state" might suggest regulatory

jurisdiction alone, and that "civil and criminal jurisdiction"

might imply only jurisdiction in the judicial sense. "Civil and
20


criminal laws and jurisdiction" more obviously includes all sorts

of jurisdiction, and can fairly lay claim to being the broadest

of the three formulations.

The only change arguably suggesting a diminution in the

scope of jurisdiction is the removal of the word "complete" from

the draft version of the bill. We think that this change, too,

may be understood as an attempt at clarification: the word

"complete" could well have been removed simply to avoid any

suggestion that the grant of jurisdiction was intended to be

exclusive. Cf. United States v. Cook, 922 F.2d 1026, 1032 (2d ___ _____________ ____

Cir.) (suggesting that "exclusive jurisdiction" and "complete

jurisdiction" may have the same connotation), cert. denied, 111 _____ ______

S. Ct. 2235 (1991). For that reason, the discrepant language is

at best inconclusive.

The small changes in phraseology pinpointed by the

Tribe, floated without visible means of support, place this case

at considerable remove from Bryan, a case in which the Court _____

confronted a genuinely suggestive lingual discrepancy, and

interpreted the final version of the statute in line with clearly

articulated legislative history. See Bryan, 426 U.S. at 379-87. ___ _____

Here, by contrast, the discrepancies that the Tribe perceives are

more conjectural than suggestive; there is absolutely nothing in

the legislative history of the Settlement Act that indicates

congressional intent either to limit the scope of state

jurisdiction or to carve a jurisdictional distinction along civil
21


regulatory/civil adjudicatory lines.9 Thus, Bryan is not a fair _____

congener.

Our assessment is reinforced by a commonsense tenet of

statutory construction. Relatively minor differences between an

Indian agreement and the ratifying act of Congress needed to give

it effect, without more, do not give rise to an inference that

Congress intended to modify the agreement. See Rosebud Sioux, ___ ______________

430 U.S. at 599 (holding that a 1904 act of Congress did not

modify a 1901 Indian agreement, despite a suggestive minor change

in language). At least when an "implied continuity in purpose"

exists between the antecedent agreement and the subsequently

enacted statute, courts should construe the latter to effectuate

the former, notwithstanding differing linguistic choices. Id. ___

So it is here, for the Settlement Act was designed to implement

the agreement embodied in the J-MEM. See, e.g., 25 U.S.C. ___ ____

1701(d) (declaring that the J-MEM "requires implementing

legislation"); Joint Hearing at 97 (acknowledging that "the

legislation as drafted intends to implement the settlement

agreement") (statement of Alan R. Parker, Gen. Counsel, Sen.

Select Comm. on Indian Affairs).

We need not belabor the obvious. Since the self-

____________________

9We do not believe the Tribe's cause is aided by the
Bureau's tentative expression of support for the position that
section 1708 excludes civil regulatory jurisdiction. See ___
Southeast Regional Solicitor's Memorandum Opinion (April 30,
1992). The Bureau's views are not entitled to any special weight
in the interpretation of statutory provisions that it is not
charged to execute. See Crandon v. United States, 494 U.S. 152, ___ _______ _____________
177 (1990).

22


serving inference drawn by the Tribe is plainly at odds with the

discernible intention undergirding the Settlement Act, and, in

the bargain, plays havoc with the statutory text, we decline

gratuitously to limit the scope of section 1708 in order to

parallel the holding in Bryan.10 Cf. United States v. Dakota, _____ ___ ______________ ______

796 F.2d 186, 188 (6th Cir. 1986) (refusing to extend Bryan _____

distinction to 18 U.S.C. 1955, because it would be

inappropriate to apply a test "developed in a different context

to address different concerns"). Hence, we conclude that the

Settlement Act granted civil regulatory jurisdiction, as well as

civil adjudicatory jurisdiction, to the state.11

C. Local Jurisdiction. C. Local Jurisdiction. __________________

We digress to add a few words about local jurisdiction,

mindful that the Town of Charlestown and certain municipal

officials are parties to this lawsuit.

Although we recognize both the town's desire to assert

jurisdiction in respect to the settlement lands and the Tribe's

opposition, we see nothing to be gained by giving separate

treatment to the question of local jurisdiction. As a general
____________________

10To the extent that the district court's opinion in Maynard _______
v. Narragansett Tribe, 798 F. Supp. 94, 98-99 (D.R.I. 1992), __________________
aff'd on other grounds, 984 F.2d 14, 15 (1st Cir. 1993), suggests _____ __ _____ _______
a contrary view, we reject it.
11Because our analysis is specific to the Settlement Act, we
need not join the debate over the general applicability of the
Bryan distinction. See United Keetoowah Band, 927 F.2d at 1176 _____ ___ _____________________
n.13 (surveying debate); see also Yavapai-Prescott Indian Tribe ___ ____ _____________________________
v. Arizona, 796 F. Supp. 1292, 1294-96 (D. Ariz. 1992) _______
(discussing applicability of Bryan distinction in respect to _____
Gaming Act).

23


matter, municipal authority is entirely derivative of state

authority, see 7A R.I. Gen. Laws 45-2-1 (1991); and in the ___

exercise of governmental powers (as opposed to proprietary

powers), municipalities act only as the agents of the state, see ___

Buckhout v. City of Newport, 27 A.2d 317, 320 (R.I. 1942). ________ _______________

It follows that if the state chooses to cede a portion

of its sovereignty to the town, the town may use that authority

to the extent of the power delegated. See, e.g., Vukic v. ___ ____ _____

Brunelle, 609 A.2d 938, 941 (R.I. 1992). But delegated powers, ________

of necessity, cannot exceed those possessed by the delegator.

The town has cited no independent basis upon which it might ___________

exercise municipal jurisdiction, and none is apparent to us.

Thus, Charlestown's concerns are necessarily subsumed in our

discussion of the state's jurisdiction.

VII. THE REACH OF THE GAMING ACT VII. THE REACH OF THE GAMING ACT

Before addressing the Tribe's ultimate argument that

the Gaming Act cancels whatever jurisdiction the Settlement Act

granted we must first consider both furcula of the state's

assertion that the settlement lands are specifically exempted

from the Gaming Act's domain.

A. The Consensual Transfer Provision. A. The Consensual Transfer Provision. _________________________________

The Gaming Act's so-called "consensual transfer"

provision, familiarly known as "section 23(d)," is the site of

the next battle. It states in relevant part:

The United States shall have exclusive
jurisdiction over criminal prosecutions of
violations of State gambling laws that are
made applicable under this section to Indian

24


country, unless an Indian tribe pursuant to a
Tribal-State compact . . . or under any other
provision of Federal law, has consented to
the transfer to the State of criminal
jurisdiction with respect to gambling on the
lands of the Indian tribe.

18 U.S.C. 1166(d). This proviso, Rhode Island asseverates,

presages an exemption applicable to the settlement lands. On

this theory, section 23(d) allows a state lawfully to assert

civil and criminal jurisdiction over gaming under either a ______

tribal-state compact or "any other provision of Federal law" that __

embodies a consensual transfer of jurisdiction. And it portrays

section 1708 of the Settlement Act as constituting such an agreed

transfer.

This interpretation signifies a promiscuous elevation

of hope over reason, for it completely overlooks two limitations

that are apparent on the face of the statute. First, section

23(d) is a penal provision that in terms deals only with criminal

prosecutions; it has no implications for civil jurisdiction

(whether regulatory or adjudicatory). Second, section 23(d)

pertains only to "gambling," which is defined for purposes of

that section as excluding any kind of "gaming." See 18 U.S.C. ___

1166(c). Thus, properly understood, section 23(d) allows states

to exercise jurisdiction pursuant to a consensual transfer only

to enforce criminal laws that proscribe gambling activities

falling outside the sanctuary of the Gaming Act. This is of no

assistance to Rhode Island, which seeks to assert unfettered

jurisdiction (including civil regulatory jurisdiction) over

25


activities constituting class II and class III gaming.12

B. Decrypting the Legislative History. B. Decrypting the Legislative History. __________________________________

Next, the state attempts a flanking maneuver. Without

meaningful citation to the Gaming Act's text, the state hawks the

proposition that Congress, in passing the Act, intended to leave

intact the grant of jurisdiction tendered a decade earlier in the

Settlement Act. And to fill the forensic void left by the utter

absence of any statutory language to this effect, the state

pushes forward carefully selected snippets of legislative

history. There are two significant problems with this approach.

In the first place, courts must look primarily to

statutory language, not to legislative history, in determining

the meaning and scope of a statute. See, e.g., United States v. ___ ____ _____________

Turkette, 452 U.S. 576, 580 (1981); Consumer Prod. Safety Comm'n ________ _____________________________

v. GTE Sylvania, Inc., 447 U.S. 102, 108 (1980); United States v. __________________ _____________

Char