Tribal immunity from state lawsuits
Michigan v. Bay Mills Indian Community
In brief
Bay Mills won on immunity: the Supreme Court agreed that Michigan’s suit was barred.
- Where it stands
- Decided
Decided 5-4 · May 27, 2014 · Opinion by Justice Kagan
- What it’s about
- Michigan sued the Bay Mills Indian Community, alleging that gambling at a casino outside Indian lands violated federal gaming law.
- Who it affects
- The decision barred Michigan’s suit against Bay Mills on immunity grounds, but did not decide whether the alleged gambling violated federal law.
Summary: written with AI from the case record.

What it's about
The Supreme Court ruled that the tribe’s immunity from suit barred Michigan’s case, agreed with the Sixth Circuit, and sent the case back to the lower court (remanded).
The case concerned whether tribal immunity protected a tribe from a state lawsuit over activity alleged to occur outside its lands.
Question presented
1. Does a federal court have jurisdiction over activity that violates the IGRA, but takes place outside of Indian lands? 2. In such a case, does tribal sovereign immunity prevent a state from suing in federal court?
What the Court decided
Holding
Michigan’s suit against Bay Mills is barred by tribal sovereign immunity. 695 F. 3d 406, affirmed and remanded.
- Result
- Affirmed
The vote
- Joined the judgment
- Dissented
- Wrote an opinion
- Majority · 5joined the Court's opinion
From the opinions
“Nevertheless, the Court turns down a chance to rectify its error.”
What's next
The Supreme Court’s review is complete, and its decision leaves the Sixth Circuit’s ruling in place.
Documents
Opinions
Docket activity
New analysis added
AI analysis generated: Case Briefing
AI analysis generated: Decision Record
Case data updated: summary, question_presented, generation_metadata
Case data updated: question_presented, extraction_metadata
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Opinion added: Opinion
Sources
Primary materials plus reporting. Best-effort analysis: this explainer relies on a mix of primary materials and trusted secondary sources. Official filings and opinions remain authoritative.