Hollywood Mobile Estates Ltd. v. Seminole Tribe
2011 U.S. App. LEXIS 10354
| 11th Cir. | 2011Background
- Seminole Tribe leased reservation lands to Antonucci in 1969; Interior approved the lease; rent based on income or a minimum annual amount with certified gross receipts.
- In 1986, De Anza Properties assigned the lease to Hollywood Mobile Estates; estoppel agreement approved by Tribe and Secretary; Hollywood paid $400,000 and 15% of gross income as rent.
- Hollywood ultimately managed the mobile home park; Tribal alleged lease defaults in 2008, including improper accounting and encumbrance; Tribe repossessed the property.
- Hollywood sought emergency relief in district court; eviction occurred before ruling; administrative proceedings ensued with Keel denying lease cancellation, Tribe appeal pending.
- Hollywood amended its complaint seeking APA mandamus relief to compel enforcement; district court dismissed; appellate issues centered on standing and prudential considerations.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Constitutional standing to sue Secretary | Hollywood asserted injury traceable to Secretary's actions. | Secretary's actions did not causally injure Hollywood. | Hollywood lacked Article III standing; dismiss for lack of jurisdiction. |
| Prudential standing under 25 U.S.C. § 415 | Hollywood falls within the zone of interests protected by § 415. | Hollywood is not within the protected zone for nontribal lessees. | Hollywood lacked prudential standing; leave to amend was futile. |
| Amended complaint construed under APA | Amendment sought an APA mandatory injunction to enforce the lease. | Remedy is limited to mandamus; APA relief not applicable as framed. | Amendment construed as APA mandatory injunction; relief available via APA but superseded by standing. |
Key Cases Cited
- Lujan v. Defenders of Wildlife, 504 U.S. 555 (1992) (irreducible elements of standing: injury, causation, redressability)
- Doe v. Pryor, 344 F.3d 1282 (11th Cir. 2003) (traceability required; injury must be connected to defendant's action)
- Focus on the Family v. Pinellas Suncoast Transit Auth., 344 F.3d 1263 (11th Cir. 2003) (standing inquiry requires plaintiff's injury to be traceable to defendant)
- Nat'l Credit Union Admin. v. First Nat'l Bank & Trust Co., 522 U.S. 479 (1998) (zone of interests test; query whether interests protected by statute align with plaintiff)
- Rosebud Sioux Tribe v. McDivitt, 286 F.3d 1031 (8th Cir. 2002) (nontribal lessee lacks standing under § 415; protects Indian interests)
- Independence Mining Co. v. Babbitt, 105 F.3d 502 (9th Cir. 1997) (treats duplicative remedies when APA relief exists)
- Japan Whaling Ass'n v. Am. Cetacean Soc'y, 478 U.S. 221 (1986) (comparing mandamus and APA relief bases for agency action)
- DiMaio v. Democratic Nat'l Comm., 520 F.3d 1299 (11th Cir. 2008) (jurisdictional standing principles; cannot create jurisdiction by hope)
- S. Pac. Transp. Co. v. Brown, 651 F.2d 613 (9th Cir. 1980) (causation and redressability principles in standing)