Halona v. MacDonald

The Navajo Tribal Council passed an interim budget resolution, CAP-32-77, to fund Chairman Peter MacDonald's (defendant) legal expenses, but that resolution bypassed the budget-and-finance-committee approval process required by an earlier resolution, CF-18-77. Eldon Hansen (plaintiff) sued to enjoin the interim appropriation as invalid because it violated the earlier, still-binding procedural requirement. The District Court of Shiprock agreed and enjoined MacDonald from spending the funds; MacDonald appealed, arguing Navajo courts lacked jurisdiction to review tribal council decisions at all.