HomeMy WebLinkAbout13.F.1. Consent Decree of BIA approval of the Trust Application of the Mdewakanton Sioux Community
13.F. J.
CITY OF SHAKOPEE
Memorandum
TO: Mayor and City Council
FROM: Mark McN eill, City Administrator
SUBJECT: Consideration of Consent Decree regarding Bureau of Indian Affairs
approval of the Trust Application of the Mdewakanton Sioux Community
DATE: December 2, 2008
Introduction:
The Council is asked to agree to the conditions contained in a consent decree that has
been negotiated between attorneys for the Bureau of Indian Affairs and attorneys
representing the City, and to authorize the City's attorneys to execute the consent decree.
This relates to the City's challenge of a ruling ofthe BIA on the 2000 fee to trust
application submitted by the Shakopee Mdewakanton Sioux Community (SMSC).
Background:
On June 7, 2007, then Assistant Secretary for Indian Affairs Carl Artman approved
placing into Trust status some 752 acres ofland which were the subject of an application
by the SMSC. Approximately 572 acres of the land is located within the City of
Shakopee.
On October 29,2007, the City brought an action which sought injunctive relief from the
decision. The City alleged that the placing of this land into trust violated the 1934 Indian
Reorganization Act, and also provisions of the National Environmental Policy Act
(NEP A). After the City filed its action, the BIA held in abeyance the transfer of title, until
the City's legal challenge was settled.
Acting on the City's behalf, the law firm ofPerkins-Coie has met on several occasions
with attorneys for the Department of the Interior, and have negotiated a tentative
settlement of the case.. The City Council is now asked to agree to the conditions contained
therein. Assuming both the City and the Department of the Interior (of which the Bureau
of Indian Affairs is a division), assent to the Consent Decree, a judge would then issue a
consent decree memorializing the agreement.
AGREEMENT
In summary, the City agrees that the 752 acres which had been the subject ofthe June
2007 decision will be placed into trust status. The Department ofthe Interior (and BIA)
agrees that there will be a different process for future SMSC fee to trust applications
which will include opportunities for input by and negotiations with the City. In addition,
the City will be a direct participant in NEP A review of future fee to trust applications.
Specifically, the major conditions are as follows:
1. The Midwest Regional Office (MRO) oftheBIA shall advise the City in writing
within fifteen days ofthe MRO's receipt of any written request (whether complete or
incomplete) submitted by the SMSC for Shakopee land to be taken into trust.
2. Within thirty days, the MRO will invite both the City and the SMSC to a meeting, at
which discussions regarding concerns or potential sources of disagreement about the
application maybe held. The SMSC is under no obligation to attend those meetings, but
the MRO would be required to meet with the City.
3. Future SMSC trust land application requests shall cause the MRO to issue a request
for information from the City regarding tax impacts, jurisdictional problems, and
potential conflicts of land use. There will also be a concurrent issuance of notice of
availability ofthe Environmental Assessment, or an Environmental Impact Statement
(EIS) if either review is required under NEP A.
4. If the BIA determines that an EIS is required, the City shall be invited to participate as
a "cooperating agency." The City shall provide any comments on the draft EA within
thirty days of receipt. If a meeting is requested by the City, the MRO shall invite the
SMSC to attend said meeting between the City and MRO.
5. In an EIS, the City shall identify issues it considers necessary to be addressed under
NEP A. For both an EA and EIS, the BIA shall consider "cumulative impacts" of Trust
land applications. Cumulative impacts are those that result not just from the specific
request, but those that are the result of the current action in combination with previous
actions and potential future actions.
6. The Department of the Interior will stipulate that the SMSC proposed use of the
subject 752.41 acres did not include gaming, and that the decision did not analyze
whether the 752.41 acres qualify for gaming under the Indian Gaming Regulatory Act.
Finally, the City would dismiss its action, although it could be reinstituted in the future if
the terms of the consent decree are not complied with by the BIA. The City also agrees to
waive any claims to fees or cost associated.
Relationship to Visioning:
This supports Goal D: (Vibrant, Resilient, and Stable).
Recommendation:
In view of the concessions made by both sides, we see that this is a fair settlement of the
issue. For that reason, I recommend that the City Council authorize the attorneys
representing the City to agree to the conditions outlined in the Consent Decree.
Action Required:
If the Council concurs, it should, by motion, authorize the attorneys representing the City
of Shakopee to enter into the Consent Decree between the City of Shakopee and the
United States Department of the Interior, et.a!. settling the City's appeal of the June, 2007
decision to take land into Trust.
}~~
Mark McNeill
City Administrator
MM:cn
DRAFT
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
THE CITY OF SHAKOPEE,
MINNESOTA
Plaintiff,
v.
CIVIL ACTION NO. 1:07-cv-01950-RMU
THE UNITED STATES OF AMERICA,
DIRK. KEMP THORNE, in his official
capacity as Secretary ofthe Interior, U.S.
Department ofthe Interior, and CARL 1.
ARTMAN, in his official capacity as
Assistant Secretary for Indian Affairs, U.S.
Department of the Interior,
Defendants.
CONSENT DECREE
"""WHEREAS, on June 7, 2007, the Assistant Secretary for Indian Affairs issued a
decision to acquire approximately 752.41 acres ofland in trust for the Shakopee
Mdewakanton Sioux Community (SMSC). The Bureau oflndian Affairs (BIA)
published notice of the trust acquisition in the Federal Register on September 27,2007.
Of this land, approximately 572 acres are located within the City of Shakopee,
Minnesota;
WHEREAS, the City of Shakopee, Minnesota, commenced this action for
declaratory' and injunctive relief on October 29, 2007, against the Department of the
Interior, Secretary ofthe Department of the Interior, and the Assistant Secretary for
Indian Affairs (collectively referred to as "Interior") challenging the June 7, 2007
decision;
WHEREAS, the City alleges that Interior unlawfully acquired the land in trust in
violation ofthe Indian Reorganization Act (IRA), 25 U.S.c. ~ 465, and its implementing
regulations at 25 C.F .R. Part 151, the National Environmental Policy Act (NEP A), 42
U.S.C. ~~ 4311 - 4347, and its implementing regulations at 40 C.F.R. Part 1500, and the
Administrative Procedure Act(AP A), 5 U.S.C. ~~ 701-706;
WHEREAS, Interior has voluntarily stayed the transfer of title to the land at issue
in this case pursuant to 25 C.F.R. ~ 151.12(b), pending the outcome ofthis district court
litigation;
WHEREAS, the City and Interior have agreed to a settlement of this case, without
any admission offact or law, that they consider to be ajust, fair, adequate and equitable
resolution of the claims raised in this case;
WHEREAS, by entering into this Consent Decree, the City and Interior do. not
waive or limit any claim or defense on any grounds, related to any agency action that
may ensue from Interior's performance of its obligations as a result of this Consent
Decree;
WHEREAS, it is in the interest of the public, the City, Interior, and judicial
economy to resolve the claims in this lawsuit without protracted litigation;
THEREFORE, the City and Interior agree AND IT IS HEREBY ORDERED as
follows:
JURISDICTION AND VENUE
1. This Court has jurisdiction over the subj ect matter of this action, and over
the Parties hereto, pursuant to the Indian Reorganization Act, 25 U.S.C. ~ 465, the
National Environmental Policy Act, 42 U.S.C. ~~ 4321-4347, and the Administrative
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Procedure Act, 5 U.S.C. ~~ 701-706, and 28 V.S.C. ~ 1331. Venue is proper in this
Court pursuant to 28 U.S.C. ~ 1391 (e) in that a substantial part of the events or omissions
giving rise to the claim occurred in this judicial district.1
AGREEMENT
2. The Midwest Regional Office (MRO) ofthe BIA shall advise the City in
writing within 15 days ofMRO's receipt of any written requests submitted by the SMSC
to have lands within the jurisdictional limits of the City taken into trust, including
requests that are complete or incomplete, unless the acquisition is mandated by law.
MRO may satisfy the notice requirement of this paragraph by providing the City, within
15 days of receipt of any SMSC trust request, a copy of a letter from MRO to the SMSC
acknowledging receipt of the trust land acquisition request.
3. Upon MRO's receipt of a complete or incomplete SMSC trust land
acquisition request as described in Paragraph 2 above, MRO shall, within 30 days, invite
the SMSC and the City to a meeting to engage in direct and good faith discussions
regarding any concerns or potential sources of disagreement regarding the request, and
MRO shall meetwith the City regardless of whether SMSC agrees to attend. The City
shall structure the meeting so that the Minnesota Open Meeting Law, Minn. Stat. S~
13D.01-13D.07, public meeting requirement is not applicable or MRO shall not attend.
4. For future SMSC trust land acquisition requests as described in Paragraph
2 above, MRO shall issue a written request for information from the City pursuant to 25
C.F.R. ~ 151.1 O( e), regarding the impact of removing land from the tax rolls, and
~ 151.1 O( f), regarding jurisdictional problems and potential conflicts of land use,
1 All citations in this Consent Decree to laws and regulations shall refer to the 2008
version of such law or regulation.
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concurrent with the issuance of a notice of availability of an Environmental Assessment
(EA) pursuant to 43 C.F.R. S 46.305 or concurrent with the issuance of a notice of
availability of a draft Environmental Impact Statement (ElS) pursuant to 43 C.F .R. S
46.435(a), should the BIA determine that an EA or EIS is required under NEP A.
5. IfBIA determines that an EIS is required or appropriate for use in
analyzing future SMSC trust land acquisition requests as described in Paragraph 2 above,
the City shall be invited to participate as a cooperating agency, pursuant to 40 C.F.R. s~
1501.6, 1508.5, and 43 C.F.R. s~ 46.225, 46.230, and MRO shan work with the City to
develop and adopt a memorandum or memoranda of understanding concerning input by
the City pursuant to 43 C.P.R. S 46.225( d). If an EA will be used to analyze future
SMSC trust land acquisition requests as described in Paragraph 2 above, MRO shall
provide to the City a draft EA on the proposed trust acquisition. The City shall provide
any comments on the draft EA within 30 days of the City's receipt of such document, and
no extensions will be granted. If the City's comments include a request for a meeting,
MRO shall invite the SMSC to attend a meeting with the City and MRO and shall meet
within thirty (30) days ofMRO's receipt of such comments and meeting request,
regardless of whether SMSC agrees to attend. The City shall structure the meeting so
that the Minnesota Open Meeting Law, Minn. Stat. SS 13D.01-13D.07, public meeting
requirement is not applicable or MRO shall not attend.
6. For any EA or EIS conducted as part of the review of future trust land
acquisition requests as described in Paragraph 2 above, BIA shall conduct an analysis of
cumulative effects, as defined under 40 C.F.R. S 1508.7, pursuant to NEP A. BIA shall
identify reasonably foreseeable future actions through consultation with and documents
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obtained from the SMSC, for example, zoning ordinances and tribal resolutions regarding
development on SMSC lands.
7. During the scoping process for an EIS, the City shall identify issues that it
considers necessary to address under NEP A. In the City's comments on a draft EA, the
City shall identify issues that it believes have not adequately been addressed in the draft
EA under NEP A. These issues may include, but are not limited to: (a) the cumulative
effects analysis in general; (b) boundaries on the cumulative effects analysis for time and
location; (c) any changes in the use of any land acquired in trust after the effective date of
this agreement, including land identified in the June 7, 2007 decision, from the use
described in the underlying trust request application, or in any NEP A documentation for
such request, which description formed the basis of the acceptance of the land into trust;
(d) the land-use, social, and economic impacts of the proposed acquisition; and (e) other
land use issues that should be included in the cumulative effects analysis. BIA shall
consider whether such issues should be evaluated in the context of cumulative impacts
analysis or any other analysis required by NEP A for any proposed action described in
Paragraph 2 above and shall include the City's comments in the administrative record of
the proposed action.
8. Interior stipulates that the SMSC's proposed uses for the 752.41 acres
were described in the June 7, 2007 Notice of Decision and did not include gaming, and
the June 7, 2007 decision did not analyze whether the 752.41 acres qualify for gaming
under the Indian Gaming Regulatory Act (IGRA), 25 V.S.C. SS 2701-2721.
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9. Pursuant to Fed. R. Civ. P. 41 (a)(1), the City hereby dismisses with
prejudice all claims and causes of action asserting that the land was taken into trust in
violation of the IRA, NEP A, the AP A or any other law or regulation.
10. Nothing in this Consent Decree shall be interpreted to obligate Interior to
pay funds in contravention ofthe Anti-Deficiency Act, 31 U.S.C. S 3141, or take any
action in contravention of the IRA, NEPA, the AP A or any other law or regulation.
11. The City does not waive any right it may have to bring suit against Interior
for any violations oflaw for any future trust land acquisitions on behalf of the SMSC or
any of its members.
12. The City agrees to waive any claim to attorneys' fees and/or costs
associated with this case.
13. The undersigned attorneys certify that they are fully authorized to enter
into and execute the terms and conditions of this Consent Decree, and to legally bind
such Party to its terms. By the signatures below, the Parties consent to entry of this
Consent Decree.
Presented and Agreed to by:
Respectfully submitted,
Benjamin S. Sharp - Bar # 211623
Donald C. Baur - Bar # 393621
Jena A. MacLean - Bar # 479910
PERKINS COlE LLP
607 Fourteenth Street, N.W.
Washington, D.C. 20005-2011
(202) 628-6600
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Federal Counsel
ENTERED this day of ,2008.
Judge Ricardo M. Urbina
United States District Court
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CERTIFICATE OF SERVICE
I HEREBY CERTIFY that copies of the foregoing CONSENT DECREE, in the matter
of City of Shako pee, Minnesota v. The United States of America et al., Civil Action No.
1 :07-cv-01950-RMU, were served this _ day of November, 2008, via Certified Mail,
to each of the following:
Gina L. Allery
Dirk Kempthorne Trial Attorney
Secretary of the United States Environment & Natural Resources
Department of the Interior Division
1849 C. Street, N.W., Room 6156 Indian Resources Section
Washington, D.C. 20240 P.O. Box 44378
(202}208-7351 L'Enfant Plaza Station
Washington, D.C. 20026-4378
George Skibine
Acting Deputy Assistant Secretary for
Policy and Economic Development
United States Department of the
Interior,
1849 C. Street, N.W., Room 4160
Washington, D.C. 20240
(202) 269-4464
Benjamin S. Sharp - Bar # 211623
Donald C. Baur - Bar # 393621
J ena A. MacLean - Bar # 479910
PERKINS COIE LLP
607 Fourteenth Street, N.W.
Washington, D.C. 20005-2011
(202) 628-660