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Lac du Flambeau Band of Lake Superior Chippewa Indians v. Coughlin

Docket: 22-227 Decision Date: 2023-06-15
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How to read this page

Below are plain-language sections to help you understand what the Court decided in Lac du Flambeau Band of Lake Superior Chippewa Indians v. Coughlin and why it matters. Quotes are taken from the syllabus (the Court’s short summary at the start of the opinion).

Summary

A short, plain-English overview of Lac du Flambeau Band of Lake Superior Chippewa Indians v. Coughlin.

The Supreme Court decided that the Bankruptcy Code unambiguously abrogates the sovereign immunity of all governments, including federally recognized Indian tribes. This decision arose from a case involving the Lac du Flambeau Band of Lake Superior Chippewa Indians and a payday loan extended to Brian Coughlin. The First Circuit's decision, which concluded that the Code strips tribes of their immunity, was affirmed.

Holding

The single most important “bottom line” of what the Court decided in Lac du Flambeau Band of Lake Superior Chippewa Indians v. Coughlin.

The Court held that the Bankruptcy Code unequivocally abrogates the sovereign immunity of all governments, including federally recognized Indian tribes.

Constitutional Concepts

These are the Constitution-related themes that appear in Lac du Flambeau Band of Lake Superior Chippewa Indians v. Coughlin. Click a concept to see other cases that involve the same idea.

  • Why State Sovereign Immunity is relevant to Lac du Flambeau Band of Lake Superior Chippewa Indians v. Coughlin

    The case primarily deals with the abrogation of sovereign immunity, specifically tribal sovereign immunity, under the Bankruptcy Code.

    Syllabus excerpt (verbatim)
    Held: The Bankruptcy Code unambiguously abrogates the sovereign immunity of all governments, including federally recognized Indian tribes.
  • Why State–Federal Power is relevant to Lac du Flambeau Band of Lake Superior Chippewa Indians v. Coughlin

    The case involves the allocation of authority between federal law and tribal sovereignty, as it interprets the reach of federal bankruptcy law over tribal entities.

    Syllabus excerpt (verbatim)
    The Bankruptcy Code unequivocally abrogates the sovereign immunity of any and every government with the power to assert such immunity.

Key Quotes

Short excerpts from the syllabus in Lac du Flambeau Band of Lake Superior Chippewa Indians v. Coughlin that support the summary and concepts above.

  • The Bankruptcy Code unambiguously abrogates the sovereign immunity of all governments, including federally recognized Indian tribes.
  • The definition of 'governmental unit' exudes comprehensiveness.
  • Congress need not use any particular words to pass this clear-statement test.

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