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Dawavendewa v. Salt River Project Agricultural Improvement and Power District

United States Court of Appeals for the Ninth Circuit

276 F.3d 1150 (9th Cir. 2002)

Relevant factsFree

SRP (defendant) leased land from the Navajo Nation under a lease requiring SRP to give hiring preference to local Navajos; Dawavendewa (plaintiff), a Hopi denied an interview, sued SRP for Title VII discrimination, and SRP moved to dismiss for failure to join the Nation, which held sovereign immunity and could not be joined without its consent. The district court agreed the Nation was indispensable and dismissed the complaint; Dawavendewa appealed.

IssueFree

Whether a lawsuit must be dismissed if an indispensable party cannot be joined.

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