Little Coyote v. United States Department of the Interior

MEMORANDUM *

Eugene Little Coyote is the former President of the Northern Cheyenne Tribe. He was removed from office by the Tribal Council during an allegedly uncon *717 stitutional special session. Following his ouster the Tribal Trial Court and Tribal Constitutional Court issued contradictory decisions regarding the validity of his removal. Subsequently, Edward Parisian, Rocky Mountain Regional Director for the Department of the Interior, Bureau of Indian Affairs (“BIA”), approved budget resolutions and recognized the Vice President, Rick Wolfname, as the interim President of the Northern Cheyenne Tribe (the “Parisian Decision”). Parisian explained in his decision that he was prompted to act by the need to resolve the impasse threatening the ability of the Tribe to perform basic governmental functions.

Little Coyote sued the BIA in federal district court seeking an injunction preventing implementation of the Parisian Decision and preventing the BIA from withdrawing its recognition of Little Coyote as the President of the Northern Cheyenne Tribe. During the pendency of this litigation, the Northern Cheyenne Tribe held a presidential election in which Little Coyote ran and was…