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Tribal immunity from state lawsuits

Michigan v. Bay Mills Indian Community

Updated Oct 18, 2026

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.

Illustration for Michigan v. Bay Mills Indian Community
Conceptual illustration · AI-generated

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
  1. Breyer
  2. Kaganwrote the opinion
  3. Kennedy
  4. Sotomayoralso wrote separately
  5. Roberts
Dissenting · 4disagreed with the result
  1. Thomaswrote a dissent
  2. Scaliawrote a dissent
  3. Ginsburgwrote a dissent
  4. Alito
5 justices joined the judgment, 4 dissented.

From the opinions

“Nevertheless, the Court turns down a chance to rectify its error.”

— Justice Thomas(dissent)

What's next

The Supreme Court’s review is complete, and its decision leaves the Sixth Circuit’s ruling in place.

Documents

1

Opinions

View the full docket on supremecourt.gov

Docket activity

6
  • New analysis added

    Oct 18, 2026 · Court records

  • AI analysis generated: Case Briefing

    Oct 18, 2026 · Generated

  • AI analysis generated: Decision Record

    Oct 18, 2026 · Generated

  • Case data updated: summary, question_presented, generation_metadata

    Oct 18, 2026 · Court records

  • Case data updated: question_presented, extraction_metadata

    Oct 17, 2026 · Court records

Show 1 more
  • Opinion added: Opinion

    May 27, 2014 · Court records

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.

Checked Oct 18, 2026Methodology

Court records and filings

Reporting and analysis