Cook Inlet Region v. Rude

Under 28 U.S.C. § 1331, federal district court courts have federal question jurisdiction over non-frivolous claims arising under the Alaska Native Claims Settlement Act ("ANCSA"), even where the ANCSA incorporates state law.

Cook Inlet Region, Inc. ("CIRI") brought two claims against Rude and Rudolf under provisions of the Alaska Native Claims Settlement Act ("ANCSA"), one of which incorporated Alaska state law. “The district court held that it had federal question jurisdiction over the ANCSA claims and supplemental jurisdiction over the state-law claims.” The Ninth Circuit noted that both causes of action arose under ANCSA and that there was no independent state law cause of action available to CIRI. The Court also noted that neither of CIRI’s ANSCA claims was frivolous. Finally, the Court noted, § 1601(F) of ANCSA limited only challenges to “elimination of Native Alaskan land claims under ANCSA, but it [did] not limit [28 U.S.C.] § 1331 federal question jurisdiction over other claims brought under ANCSA.” The Ninth Circuit held that there was federal question jurisdiction under § 1331 over the ANCSA claims. AFFIRMED.