San Diego Law Review


Library of Congress Authority File


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The issue of sovereign immunity is becoming an increasingly important one as tribes that were traditionally impoverished and isolated reach out and do business around the country. On the one hand, tribes have been focusing on a few, specific businesses "includ[ing] ski resorts, gambling, and sales of cigarettes to non-Indians." But more recently, as the 1998 Supreme Court case of Kiowa Tribe v. Manufacturing Technologies, Inc. notes, the "modern, wide-ranging tribal enterprises extend[] well beyond traditional tribal customs and activities." This creates some initial difficulties. Non-tribal corporations may be hesitant

to do business with tribal corporations, which themselves may be

hesitant to give up the powerful tool of sovereign immunity. Non- tribal corporations also face complex jurisdictional issues and may be

required to sue in tribal court.'

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