Judge Quist in the Western District of Michigan recently remanded a tort claim back to tribal court in accordance with the tribal court exhaustion doctrine, as articulated in National Farmers Union and Iowa Mutual.
The case is called Michigan Property & Casualty Guaranty Association v. Foucault-Funke American Legion Post 444.
The motion to dismiss is here: Memorandum in Support of Motion
The response brief is here: Response Brief
Judge Quist’s opinion remanding the case to tribal court is here: Opinion