Table Mountain Rancheria Association v. Andrus
- William Orrick
- 3:80-cv-04595
- U.S. District Court · Northern District of California
- 16
In Gloria Walker v. Doug Burgum, Judge Orrick denied the motion to enforce a 1983 judgment as untimely and beyond the court’s jurisdiction.
The individual movants seeking to enforce the 1983 stipulated judgment, and the federal officials and agencies opposing the motion, were affected by the denial. The order left the requested recognition and governance-related relief unavailable in this proceeding.
What happened
In Gloria Walker v. Doug Burgum, individuals who said they were members or descendants of the historic Table Mountain Band of Indians sought to enforce a 1983 stipulated judgment involving the Table Mountain Rancheria. They argued that federal officials had failed to recognize and work with the broader historic tribal entity rather than a group centered on people covered by the judgment’s distribution plan.
The court found two decisive problems: the movants were not parties to the earlier case or members of either class covered by the judgment, and they waited decades to file. The court said the motion was barred by the six-year deadline for claims against the federal government and that the court’s authority to oversee the judgment had ended one year after its entry. It also rejected the movants’ reliance on a rule allowing relief from a judgment because they sought enforcement, not relief from the judgment, and had not shown an extraordinary reason for the delay.
Judge William H. Orrick denied the motion, stating both that it was untimely and that the court lacked jurisdiction to grant the requested relief. The order stated that the motion was denied without leave to amend.
The detailed version
- Table Mountain Rancheria Association v. Andrus · No. 3:80-cv-04595
- William Orrick
- July 23, 2025
Background
In 1983, the court entered a stipulated judgment in an earlier related proceeding concerning the distribution of Table Mountain Rancheria assets, the restoration of Indian status for certain distributees, federal recognition of the Table Mountain Band of Indians, and the possible restoration of land to federal trust status. The judgment covered specified distributees and their successors, as well as a separate class of dependents of distributees. The court retained jurisdiction for one year after entry of the judgment.
More than four decades later, individual movants who said they were members or descendants of the historic Table Mountain Band of Indians filed a motion under Federal Rule of Civil Procedure 60(b)(6) and sought enforcement of the 1983 stipulated judgment. They said the Bureau of Indian Affairs and other Interior Department officials had improperly conducted government-to-government relations with the Table Mountain Rancheria, whose membership they said was centered on distributees and their dependents, rather than with the broader historic tribal entity. The movants sought an order requiring the government to recognize and work with that historic entity.
The individual movants were not plaintiffs in the earlier related proceeding and were not members of either class created by the 1983 judgment. The Table Mountain Rancheria Association had been a plaintiff in that proceeding but was not a member of either distributee class.
Timeliness
The court held that the motion was untimely. Under 28 U.S.C. § 2401(a), civil actions against the United States generally must be filed within six years after the claim arises. The court concluded that the relevant events occurred decades earlier. It pointed to the 1983 judgment and the federal notice issued later that year, which identified the Table Mountain Rancheria as the federally recognized tribal entity. At the latest, the court found that the movants were on notice of their alleged injury by October 1, 1998, when a federal official acknowledged the Tribe’s amended constitution, which excluded Gloria Walker and her descendants from membership. The movants waited another 26 years before filing.
The movants argued that the Administrative Procedure Act’s provision allowing courts to compel agency action unlawfully withheld or unreasonably delayed could excuse the delay. The court rejected that argument because the movants had not brought an Administrative Procedure Act claim. The court also rejected arguments that the judgment’s continuing effect, the claimed ongoing injury, or the importance of the constitutional issues made the motion timely.
Jurisdiction
The court separately held that it lacked jurisdiction to grant the requested relief. Enforcement of a settlement or stipulated judgment generally requires an independent basis for federal jurisdiction. Ancillary jurisdiction—limited authority over matters connected to a case already properly before the court—can sometimes support enforcement when the court incorporated settlement terms into its dismissal order or expressly retained jurisdiction. Here, the stipulated judgment retained jurisdiction for only one year, and that period had expired in 1984.
The court also held that the movants were not the proper parties to enforce the judgment because they were not members of the certified classes. Rule 60(b)(6), which permits relief from a final judgment for another reason that justifies relief, did not provide a basis for the requested enforcement because the movants were not seeking to be relieved from the judgment. Even if the rule applied, the court said the motion was not filed within a reasonable time and the movants had not shown extraordinary circumstances excusing the decades-long delay. The delay also prejudiced the government because records and witnesses had become harder to locate.
Disposition
Judge William H. Orrick denied the motion. The order states that the motion was untimely and that, even if it were timely, the court would lack jurisdiction to grant the requested relief. The motion was denied without leave to amend.
Read the full 16-page opinion on CourtListener, the free public archive maintained by the Free Law Project.