Iowa Mutual Insurance Co. v. LaPlante

Edward LaPlante (defendant), a Blackfeet tribal member, was injured on the reservation while working for Wellman Ranch, a Montana corporation owned by tribal members, and sued Wellman and its insurer, Iowa Mutual Insurance Company (plaintiff), in tribal court, which asserted jurisdiction over Iowa Mutual as a non-Indian doing business with tribal members on the reservation. Iowa Mutual then sued in federal court based on diversity jurisdiction, seeking a declaration that it owed no duty to defend or indemnify Wellman, and arguing it did not need to exhaust tribal remedies first because its claim rested on diversity rather than a federal question; the district court and Ninth Circuit disagreed and required exhaustion.