Here is the complaint in Stand Up for California v. DOI (D. D.C.):
Stand Up for California Complaint
An excerpt:
This “reservation shopping” case involves a dispute over the Secretary of the United States Department of Interior’s decision to acquire 305.49 acres (the “Casino Parcel”) in trust on behalf of the North Fork Rancheria of Mono Indians (the “North Fork Tribe” or the “Tribe”) under 25 U.S.C. § 465 for the purpose of enabling the Tribe to develop and operate a mega-casino funded by Las Vegas-based Station Casinos, Inc. (“Station Casinos”) almost 40 miles from the Tribe’s reservation. The Tribe already has ancestral lands in trust on which gambling can occur, and therefore the Secretary’s decision has been highly controversial and widely opposed. As is explained in detail below, the decision was arbitrary, capricious, an abuse of discretion, and was not in accordance with the federal policy strongly favoring on-reservation gambling, and the limited exception for off-reservation Indian gambling. Indeed, the Casino Parcel was strategically chosen adjacent to State Route 99 to provide easy access to nearby metropolitan areas with large numbers of potential gamblers.
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