Ramirez

Since the Seminole Tribe of Florida opened its first bingo hall in 1979 and succeeded in blocking legal challenges to the hall’s operation, the Indian gaming industry has seen a meteoric rise in popularity and profitability. According to data from the National Indian Gaming Commission, revenues from Indian gaming nationwide rose from about $5.4 billion in 1995 to about $19.4 billion in 2004.

Unquestionably, these figures reflect a substantial increase in the number of non-Indians entering and engaging in activities on Indian land. This ever-increasing influx of people onto reservations and rancherías throughout the country is probably nowhere more prevalent than in California, where, at the end of 2006, 54 tribes were conducting gaming operations in 56 locations across the state.

Unfortunately, more people on Indian land means a greater potential for crime on Indian land, which raises interesting and difficult questions about the role of—and limitations on—tribal police officers involved in investigating suspected criminal activities and the use of evidence obtained by those officers. This case raises one such question, namely, whether the exclusionary rule applies in a…