Reich v. Great Lakes Indian Fish and Wildlife Comm'n

The Great Lakes Indian Fish and Wildlife Commission (defendant), created by Chippewa tribes to enforce their fishing, hunting, and gathering rights, employed field officers who worked long hours during peak seasons and less during slower periods, without being paid overtime. The Department of Labor (plaintiff) sued to enforce a subpoena against the Commission under the Fair Labor Standards Act (FLSA), and the Commission argued the FLSA did not apply to Indian agencies; the district court agreed with the Commission and declined to enforce the subpoena, and the Department appealed.