Chelsea Farrer And Chad Young V Waneka Rosebud Cornpeach

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Automated Summary

Key Facts

Plaintiffs Chelsea Farrer and Chad Young were shot by Waneka Rosebud Cornpeach, an officer of the Ute Indian Tribe Fish and Wildlife Department. They filed tort claims (assault, battery, false imprisonment, etc.) in Utah state court. Cornpeach removed the case to federal court citing federal question jurisdiction under 28 U.S.C. § 1331 related to tribal sovereignty. The court remanded the case to state court due to lack of subject matter jurisdiction and denied Cornpeach's motion for declaratory judgment as moot.

Issues

  • The defendant claimed the infringement doctrine (under Williams v. Lee) precluded state court jurisdiction because the alleged tort occurred on tribal land. The court rejected this, noting the infringement doctrine functions as a defense and does not independently create federal jurisdiction under § 1331. The analysis compared this to Graham v. Oklahoma Tax Commission, where tribal sovereign immunity similarly failed to establish federal jurisdiction when raised solely as a defense.
  • The court evaluated whether the defendant's removal to federal court under 28 U.S.C. § 1331 was valid, focusing on whether the plaintiffs' state-law tort claims (assault, battery, etc.) necessarily raised a federal question about tribal sovereignty. The court concluded the well-pleaded complaint rule barred federal jurisdiction because the plaintiffs' claims did not themselves assert federal issues, even though the defendant argued the infringement doctrine precluded state court jurisdiction.

Holdings

The court determined that it lacks subject matter jurisdiction under 28 U.S.C. § 1331 because the plaintiffs' state law tort claims do not present a federal question on their face. The case was remanded to Utah state court pursuant to 28 U.S.C. § 1447(c), and the defendant's motion for declaratory judgment was denied as moot.

Remedies

  • The court remands the case to the Eighth Judicial District Court in Duchense County, Utah, under 28 U.S.C. § 1447(c) because the plaintiffs' state law tort claims do not raise a federal question sufficient for federal jurisdiction.
  • The court denies Cornpeach's motion for a declaratory judgment, finding it moot due to lack of federal subject matter jurisdiction under § 1331 and the well-pleaded complaint rule.

Legal Principles

The court applied the well-pleaded complaint rule to determine that 28 U.S.C. § 1331 federal question jurisdiction could not be established based on a federal defense (infringement doctrine) raised by the defendant. The decision emphasized that the plaintiffs' state law tort claims did not present a federal issue on their face, and the court lacked subject matter jurisdiction to entertain the removal.

Precedent Name

  • Grable & Sons Metal Prods., Inc. v. Darue Eng'g & Mfg.
  • Oglala Sioux Tribe v. C & W Enters., Inc.
  • Devon Energy Prod. Co., L.P. v. Mosaic Potash Carlsbad, Inc.
  • Ute Indian Tribe v. Lawrence
  • Oklahoma Tax Commission v. Graham
  • Medesimo Tempo, LLC v. Skull Valley Health Care, LLC
  • Dutcher v. Matheson
  • Caterpillar, Inc. v. Williams
  • Becker v. Ute Indian Tribe of the Uintah & Ouray Rsvr.

Cited Statute

  • 28 U.S.C. § 1447(c) - Remand to State Court
  • 28 U.S.C. § 1441(a) - Removal of Civil Actions
  • 28 U.S.C. § 1446 - Removal Procedure
  • 28 U.S.C. § 1331 - Federal Question Jurisdiction

Judge Name

  • Daphne A. Oberg
  • Jill N. Parrish

Passage Text

  • As the Court emphasized, 'it has long been settled that the existence of a federal immunity to the claims asserted does not convert a suit otherwise arising under state law into one which, in the statutory sense, arises under federal law.' Id. at 841.
  • Under this rule, § 1331 federal question jurisdiction cannot be established 'on the basis of a federal defense... even if the defense is anticipated in the plaintiff's complaint[] and even if both parties concede that the federal defense is the only question truly at issue.' Id. at 393.
  • If Plaintiffs had pled that the incident occurred on reservation land, there is still no reason to think that Plaintiffs would be required to raise issues related to the infringement doctrine in their complaint.