Jess Wesley Crawford Diane Laplante Rodney Lane v. Genuine Parts Co., Inc. Echlin, Inc.

We consider whether federal court deference to Indian tribal courts is required when the assertion of tribal court jurisdiction comes on the eve of trial, years after the action was filed.

I

This action arose when an automobile accident occurred on December 20, 1982, on the Blackfeet Indian Reservation in Montana. Jess Crawford, Diane LaPlante, and Rodney Lane, all members of the Blackfeet Tribe, were in Crawford’s Ford Bronco when Lane, the driver, was forced to take evasive action to avoid livestock grazing on or near the road. The Bronco overturned and all three occupants were injured; Crawford was rendered a quadriplegic.

In 1984, the three injured occupants brought suit in state court against the State of Montana and various companies involved in the production, sale, or maintenance of the Bronco. Included were products liability claims against two companies, now known as Genuine Parts Company and Echlin, Incorporated, for the alleged improper manufacture and installation of brakes upon the Bronco. These two defendants are located outside of Montana.

Eventually, all but the two brake companies were settled out of the litigation. On January 13, 1987, the brake companies…