6/18/2020 National Indian Law Library (NILL) BIA has adduced no contrary evidence. Nor does it matter what Rojo’s personal net worth was at the time of ling. Under EAJA, it is the net worth of the real party in interest that matters, and a member of an organization is only a real party in interest separate from the organization for the purposes of EAJA if the member would be liable for attorney’s fees in the absence of an award, regardless of whether the member receives a bene t from a favorable merits ruling. Love v. Reilly, 924 F.2d 1492, 1494 (9th Cir. 1991). The record in this case shows that it is the Colony itself that is liable for attorney’s fees, not Rojo personally. (Colony Resolution 2018-1008, ECF No. 305-1, at 5; Colony Mins., ECF No. 305-1, at 7). The remaining question is whether the BIA’s position was “substantially justi ed.” Id. § 2412(d)(1) (A). The BIA defended primarily on the basis that the Court lacked subject matter jurisdiction over the action. The Court’s jurisdiction to require the BIA to recognize a tribal government under the APA was unclear at the time. The Court relied upon Eighth Circuit precedent, Goodface v. Grassrope, 708 F.2d 335 (8th Cir. 1983), there being none in this Circuit. The Ninth Circuit’s opinion approving jurisdiction under the APA in cases like Goodface and the present case issued after the BIA had lost on the issue here. Alto v. Black, 738 F.3d 1111, 1123–25 & n.9 (9th Cir. 2013) (citing id. at 339). The BIA reiterated its position on jurisdiction in at least one brief thereafter, but only to preserve the argument, and not in any way requiring Plaintiffs to expend additional attorney labor. (Resp. 1–2, ECF No. 251). Still, as Plaintiffs correctly note, the BIA’s position was only “substantially justi ed” for the purposes of EAJA if both the BIA’s “original action” and its “defen[se]” of its original action in court were substantially justi ed. United States v. Marolf, 277 F.3d 1156, 1161 (9th Cir. 2002). Here, only the jurisdictional defense was substantially justi ed (until 2013). The underlying refusal of the BIA to recognize a tribal government of a congressionally recognized tribe (and the failure to attempt to sort out any dispute) for several years was not substantially justi ed. Tribal leadership disputes can be complex and acrimonious, but so long as Congress continues to recognize dependent tribal sovereigns within America’s borders, the appropriate executive agency has a trust duty to those tribes, and taking sides in tribal leadership disputes, at least so far as necessary to ensure diplomatic contact, is a price of that continuing policy that the executive branch must pay. As noted, the BIA was only required to make a rational decision as to which person(s) to recognize as the tribal representative(s). It was an unjusti ed abdication of this duty to refuse to treat with the Winnemucca Indian Colony at all rather than choose which person(s) to recognize. Moreover, when ordered to select one or more representatives, the BIA then chose to recognize two persons who were ercely opposed to one another (Wasson and Bills, the latter of whom was accused by the former of having murdered the former’s father in order to assume leadership of the Colony). This action was also unjusti ed and an abuse of discretion under the APA, because choosing to recognize both Wasson and Bills was tantamount to making no choice at all. No rational person would expect the two to act harmoniously. Upon being ordered to choose again, the BIA again made an unjusti ed choice, choosing Bills, based not on any supposed ability to better work with Bills (who apparently, unlike Wasson, resided not on or near the Colony but in California) for the bene t of the Colony according to the Govrnment’s trust duty, but based on the BIA’s interpretation of tribal law, which was an improper consideration. In summary, the Court nds that the BIA’s underlying actions in this case were not substantially justi ed. https://narf.org/nill/bulletins/federal/documents/winnemucca_v_us_doi.html 2/4

Select target paragraph3