The court of appeals affirmed a judgment. The court held that tribal court jurisdiction over a nonmember was plausible, and thus exhaustion of tribal court remedies was required, where the tribe alleged civil claims for violations of its regulations against trespass onto and damage against tribal lands.
Valinda Jo Elliott set a signal fire after she became lost for several days within the White Mountain Apache Tribe’s reservation in the high desert of Arizona. The signal fire grew into a forest fire that, in conjunction with another nearby forest fire, caused substantial damage.
