Iowa Management & Consultants, Inc. v. Sac & Fox Tribe of the Mississippi in Iowa, Meskwaki Nation

BRIGHT, Circuit Judge,

dissenting.

I agree with the fundamental importance of the well-pleaded complaint rule. I also agree that routine, Indian-related contract disputes are not generally matters for the federal courts. But IMCI’s action against' the Tribe is not a routine matter, and the well-pleaded complaint rule has no application here. Indeed, *490IMCI’s complaint makes out a cause of action over which the district court should exercise jurisdiction, and I therefore dissent.

The majority opinion quotes from the complaint to support the conclusion that IMCI relied on the Tribe’s “anticipated defense” to establish jurisdiction. When read in context, however, the quoted language does not purport to establish an affirmative allegation but rather serves as an informative aside, succinctly describing for the district court just how the parties came before it. We must look beyond these passages and consider what this lawsuit is really about.

First, the Indian Gaming Regulatory Act (“IGRA”), 25 U.S.C. §§ 2701-2721, was expressly intended to “preempt the field in the governance of gaming activities on Indian lands.” S.Rep. No. 446, 100th Cong., 2d Sess. 6 (1988), reprinted, in 1988 U.S.C.C.A.N. 3076. Thus, management agreements for gaming operations, such as the agreement at issue here, incorporate the terms of the IGRA by operation of law. See Tamiami Partners v. Miccosukee Tribe of Indians, 63 F.3d 1030, 1047 (11th Cir.1995). As a result, disputes arising under such management agreements are disputes arising under the laws of the United States for which the district courts enjoy jurisdiction via 28 U.S.C. § 1331. See id.

Second, even if that were not the case, IMCI pleaded a declaratory judgment action. At bottom, its complaint makes an affirmative request for a declaration of its right to arbitrate under the contract. (Comply 12). Athough the declaratory judgment statute, 28 U.S.C. § 2201, does not alone offer an independent basis for jurisdiction, a federal court’s jurisdiction will nevertheless be established in such an action when other grounds for exercising jurisdiction are present. See TTEA v. Ysleta del Sur Pueblo, 181 F.3d 676, 681 (5th Cir.1999). Additionally, the IGRA has been held to support jurisdiction for the issuance of a declaratory judgment. See Oneida Tribe of Indians of Wis. v. State of Wisconsin, 951 F.2d 757 (7th Cir. 1991) (actual controversy under the Act warrants declaratory judgment). Most importantly for our purposes, an independent basis for jurisdiction in declaratory judgment actions may be established from the perspective of the declaratory defendant. Indeed, as the Supreme Court has noted, even where declaratory plaintiffs have not otherwise established a basis for jurisdiction, “[fjederal courts have regularly taken original jurisdiction over declaratory judgment suits in which, if the declaratory judgment defendant ] brought a coercive action to enforce its rights, that suit would necessarily present a federal question.” Franchise Tax Bd. v. Construction Laborers Vacation Trust, 463 U.S. 1, 19, 103 S.Ct. 2841, 77 L.Ed.2d 420 (1983) (noting that this approach is consistent with the nature of the declaratory remedy itself). Put another way:

To establish an independent basis for jurisdiction ... the plaintiff need not show that it would state a claim absent the declaratory judgment statute. Rather, it may show that there would be jurisdiction over a claim against it.

TTEA, 181 F.3d at 681 (citing 10B Charles Aan Wright, Arthur R. Miller & Mary Kay Kane, Federal Practice and Procedure § 2767, at 651 (1998)). Thus, to establish federal jurisdiction over its own suit for declaratory judgment, IMCI needed only to show that were IMCI the defendant in an action brought by the Tribe under the contract, jurisdiction would lie in the federal courts. In my view IMCI has made the necessary showing.

Finally, it is important to recognize that the specific declaration sought by IMCI in this case concerns the validity of the arbitration clause in its contract with the Tribe. This circuit has held that, in the absence of clear and unmistakable evidence to the contrary, a question regarding the validity of an arbitration clause is not itself subject to arbitration and is instead a matter for the courts. McLaugh*491lin Gormley King Co. v. Terminix Int’l Co., L.P., 105 F.3d 1192, 1193-94 (8th Cir. 1997) (citing First Options of Chicago, Inc. v. Kaplan, 514 U.S. 938, 943, 115 S.Ct. 1920, 131 L.Ed.2d 985 (1995)). As a practical matter then, there is no other forum in which IMCI may vindicate its rights.

For these reasons, IMCI’s complaint against the Tribe establishes jurisdiction in the federal district court to declare the rights of the parties under the contract and to resolve the federal questions relating to the application of the IGRA to the parties’ contractual arrangements. I would reverse and remand this case to the district court for trial.