This summary was computer-generated without any editorial revision. It is not official, has not been checked for accuracy, and is NOT citable.
Facts
The Plaintiff, a collection agency, repossessed the Defendant's vehicle from allotted Indian land in New Mexico without his written consent or a tribal court order. The Defendant, a Navajo Nation member, alleged the repossession violated Navajo law, which requires judicial process or consent for repossession on Indian land. The Plaintiff argued that New Mexico law, which permits self-help repossession, governed the case (paras 1-3).
Procedural History
- District Court, McKinley County: Applied the precedent from General Motors Acceptance Corp. v. Chischilly and granted summary judgment in favor of the Plaintiff for $18,212.41, rejecting the Defendant's counterclaim (para 6).
- Court of Appeals: Certified the case to the Supreme Court of New Mexico to determine whether Chischilly remains valid law (para 6).
Parties' Submissions
- Plaintiff-Appellee: Argued that New Mexico law governed the repossession, permitting self-help repossession without breaching the peace, and that tribal jurisdiction did not extend to allotted Indian lands (paras 3-4, 6).
- Defendant-Appellant: Contended that the repossession violated Navajo law, which requires written consent or a tribal court order, and sought damages for wrongful repossession under Navajo law (paras 3-4).
Legal Issues
- Does the civil jurisdiction of the Navajo Nation extend to allotted Indian lands outside reservation boundaries?
- Should the precedent set in General Motors Acceptance Corp. v. Chischilly be overruled?
- Which law governs the repossession: Navajo law or New Mexico law?
Disposition
- The Supreme Court of New Mexico overruled Chischilly and held that tribal court civil jurisdiction extends to allotted Indian lands within Indian Country (para 12).
- The case was remanded to the district court to determine whether Navajo law applies to the Defendant's counterclaim (para 17).
Reasons
Per Chávez J. (Maes C.J., Minzner, Serna, and Bosson JJ. concurring):
The Court overruled Chischilly, recognizing that the U.S. Supreme Court has consistently applied the definition of "Indian Country" under 18 U.S.C. § 1151 to both civil and criminal matters since Chischilly was decided. The Court held that allotted Indian lands qualify as Indian Country, conferring concurrent jurisdiction to the Navajo Nation over civil matters arising there (paras 8-12).
The Court emphasized that tribal sovereignty and self-governance are protected under federal law, and tribal courts have jurisdiction over activities on Indian Country, including allotted lands. However, the Court found that state courts also have concurrent jurisdiction in this case, as the Defendant chose to raise his counterclaim in state court, and the repossession did not exclusively arise within Indian Country (paras 13-16).
The Court remanded the case to the district court to apply choice-of-law principles to determine whether Navajo law governs the Defendant's counterclaim (para 17).