Inyo County, California v. Paiute-Shoshone Indians of the Bishop Community of the Bishop Colony

Summary

The Court held that Indian tribes are not 'persons' under § 1983 qualified to sue to vindicate sovereign immunity from state criminal processes. It vacated the Ninth Circuit's judgment and remanded to consider whether federal common law provides jurisdiction for declaratory or injunctive relief. Justice Stevens concurred in the judgment, arguing tribes qualify as persons under § 1983 but this specific claim rested on common law immunity rather than a federal right.