Santa Clara Pueblo v. Martinez

Santa Clara Pueblo tribal law denied membership to the children of female members who married outside the tribe, while imposing no such restriction on children of male members; Martinez (plaintiff), a female tribal member whose children were half Navajo, was denied tribal membership for her children and sued the Tribe (defendant) in federal court, alleging the rule's sex-based discrimination violated the Indian Civil Rights Act (ICRA). The district court upheld the rule as valid under the ICRA, implying a federal cause of action existed, and the Tenth Circuit agreed a federal cause of action existed but found the Tribe hadn't shown a compelling interest justifying the sex-based rule.