California v. Cabazon Band of Mission Indians

What happened

The Cabazon and Morongo Bands of Mission Indians occupy reservations in Riverside County, California. The Cabazon Reservation was first set apart for the Cabazon Indians by Executive Order in 1876, and in 1891 Congress declared both reservations for the "sole use and benefit" of the Bands. Each Band ran bingo games under a federally approved tribal ordinance. The games were open to the public and played mostly by non-Indians. The Cabazon Band also ran a card club.

California tried to apply its bingo statute to the Bands, and Riverside County tried to apply its bingo ordinance and its ban on draw poker and other card games. The Bands went to federal court. They won, and the Supreme Court affirmed.

The Court held that California's bingo law regulated gambling instead of prohibiting it, so Public Law 280 did not let the state enforce it on reservations. The Organized Crime Control Act did not either. State law is pre-empted when it interferes with federal and tribal interests, and the Court found the state's interest in keeping out organized crime was not enough to override the federal interest in tribal self-sufficiency. The Court noted that the tribal games provided the sole source of revenue for the operation of the tribal governments.

In a later case, the Supreme Court wrote that Congress adopted the Indian Gaming Regulatory Act (IGRA) in response to Cabazon.

Summarized with AI assistance from 3 sources and checked against their words; not yet reviewed by historians or by the nations. Report an error