Jerry Rape v. Poarch Band of Creek Indians

Summary

The court affirmed dismissal of the plaintiff's contract and tort claims arising from an alleged jackpot at a tribal casino. It held that the record did not require resolving whether the casino land was properly within tribal political jurisdiction or whether the gaming activity was federally authorized, because either tribal adjudicative jurisdiction or the illegality of the gambling activity independently foreclosed relief. The court also recognized that employees sued individually could not invoke tribal immunity merely because they worked for the Tribe. No separate opinions were filed.