Eleventh Circuit Holds Hollywood Mobile Estates Does Not Have Standing to Sue Seminole Tribe/Interior in Tribal Lands Repossession Case

Here is the opinion. And here are the briefs.

An excerpt:

This appeal presents issues of constitutional and prudential standing. The issue of constitutional standing is whether Hollywood Mobile Estates Limited alleged an injury fairly traceable to the Secretary of the Interior or redressable by the district court in a complaint that alleged that the Seminole Tribe of Florida had threatened to repossess tribal property in violation of a lease between Hollywood and the Tribe. After the Tribe repossessed the leased property, the district court denied, as futile, the motion of Hollywood for leave to amend the complaint to request injunctive relief against the Secretary under the Administrative Procedure Act, 5 U.S.C. § 551 et seq. That decision raises an issue of prudential standing: whether the interests of Hollywood are within the zone of interests protected by the Indian Long–Term Leasing Act, 25 U.S.C. § 415, and its accompanying regulations. Because we conclude that Hollywood lacked constitutional standing to maintain its complaint, we vacate in part the judgment entered by the district court and remand with instructions to dismiss for lack of subject matter jurisdiction. Because we also conclude that Hollywood lacked prudential standing to sue the Secretary, we affirm the denial of the motion for leave to amend the complaint as futile.