Here is the complaint in Cheyenne River Sioux Tribe v. Jewell (D. S.D.):
Plaintiff, an Indian Tribe operating under grants from or contracts with the United States Bureau of Indian Affairs under the Indian Self-Determination and Education Assistance Act (Public Laws 93-638 and 100-297, as amended), and upon whose reservation the Defendant directly operates a BIE-run school, seeks a permanent injunction pursuant to Fed.R.Civ.P. Rule 65, a Writ of Mandamus pursuant to 28 U.S.C. §§ 1361 and 1362, and Declaratory Relief pursuant to 28 U.S.C. § 2201 et seq., and an Order to enforce compliance with the terms of the Settlement Agreement and Stipulated Final Judgment entered by this Court in Yankton Sioux Tribe, et al. v. Kempthorne, et al, #4:06-cv-04091-KES (DSD) to enjoin Defendants from proceeding with their announced plan to restructure the Department of Interior’s Bureau of Indian Education (hereinafter “BIE”), and its subsidiary offices and staff in a manner that will reduce and/or eliminate its legal obligations to Indian Tribes, Tribal Schools, and ultimately to the individual Tribal member students of those schools, including the Plaintiff, under the United States Constitution, treaties with the various Indian tribes, federal statutes, regulations, or policies, in a manner that is arbitrary, capricious, an abuse of discretion given to the Executive Branch to carry out the United States Congress’ legislative mandates, and/or violation of federal law or regulation.