Critical commentary, I might add. From the King County Bar Association Law Bulletin:
State v Shale – Supreme Court Moves Washington in the Wrong Tribal Direction
A somewhat random excerpt:
The Court’s opinion is primarily based on its wholly mistaken belief that when Public Law 280 was passed by Congress in the 1950s and enacted and amended by Washington in the 1960s, “neither this state nor the federal government would have understood that one tribe’s court could have jurisdiction over members of another tribe.” To reach that conclusion, the Court relied upon Duro v. Reina, 495 U.S. 676 (1990), where the U.S. Supreme Court held a tribe no longer possessed the authority to prosecute a “nonmember Indian.”