The Western District of Washington rejected a claim that the Violence Against Women Act confers tribal court jurisdiction over personal protection orders issued against non-Indians. In this case, Martinez v. Martinez, the Suquamish Tribal Court had issued a PPO against a non-Indian man in favor of an Alaskan Native woman. They both lived on non-Indian-owned land on the Port Madison Reservation. The court also ruled that the tribal court exhaustion doctrine does not apply in this case.
Here are the materials:
defendant-martinez-motion-to-dismiss
suquamish-tribe-motion-to-dismiss
plaintiff-martinez-response-to-motions