Seneca Nation of Indians v. State of New York, 988 F.3d 618

In 2002 the Seneca Nation and New York executed a Class III gaming compact: 14-year initial term with an automatic 7-year renewal; the Compact exchanged geographic exclusivity for graduated revenue-sharing (State Contribution) beginning in 2002.
The Secretary of the Interior completed review in 2002 but declined to approve/disapprove, so under 25 U.S.C. § 2710(d)(8)(C) the Compact was "deemed approved" to the extent consistent with IGRA.
The Compact is silent about State Contribution during the 7-year renewal; parties made no objections, so the Compact renewed on Dec. 9, 2016.
New York demanded arbitration in 2017 after the Nation stopped payments; a three-arbitrator panel (2–1 majority) found the renewal clause ambiguous and, using extrinsic evidence, held the Nation must continue paying at 25% during renewal.
The Nation petitioned to vacate the award in district court, arguing the panel manifestly disregarded IGRA because any extension of payment obligations required separate Secretary approval; the district court confirmed the award.
The Second Circuit affirmed, holding the panel did not manifestly disregard IGRA and that referral to DOI under primary jurisdiction was not warranted.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the arbitral panel manifestly disregarded IGRA by enforcing payment obligations for the renewal term without separate Secretary approval	Nation: Panel’s extrinsic‑evidence–based interpretation created (or enforced) a term requiring new Secretary approval under IGRA, so the award should be vacated	NY: Panel merely interpreted a renewal term deemed approved by the Secretary; arbitrators addressed IGRA and did not add an amendment needing approval	Court: Panel did not manifestly disregard law—it considered IGRA, reasonably interpreted the Compact as requiring payments, and the Secretariat‑approval argument was not a well‑defined controlling legal principle
Whether the district court should have stayed proceedings and referred questions to DOI under the primary jurisdiction doctrine	Nation: If unclear whether Secretary approved the renewal payments, the court should refer the question to DOI	NY: Referral would undermine FAA’s streamlined confirmation process and parties’ agreement to arbitrate; DOI already declined to intercede	Court: Referral not warranted—contract interpretation is within judicial/arbitral expertise, FAA aims for prompt review, and DOI had declined involvement

County of Oneida v. Oneida Indian Nation of New York State, 470 U.S. 226 (U.S. 1985) (canon favoring interpretation benefiting Indian tribes)
T.Co Metals, LLC v. Dempsey Pipe & Supply, Inc., 592 F.3d 329 (2d. Cir. 2010) (standard of review for manifest disregard of law)
Schwartz v. Merrill Lynch & Co., 665 F.3d 444 (2d. Cir. 2011) (elements required to show manifest disregard)
Westerbeke Corp. v. Daihatsu Motor Co., 304 F.3d 200 (2d. Cir. 2002) (disregarded legal principle must be well defined and clearly applicable)
Hall St. Assocs., L.L.C. v. Mattel, Inc., 552 U.S. 576 (U.S. 2008) (FAA’s streamlined confirmation/ vacatur framework)
United States v. W. Pac. R.R. Co., 352 U.S. 59 (U.S. 1956) (doctrine of primary jurisdiction)
Ellis v. Tribune Television Co., 443 F.3d 71 (2d. Cir. 2006) (factors for applying primary jurisdiction)
Chicago, R.I. & P. Ry. Co. v. Denver & R.G.R. Co., 143 U.S. 596 (U.S. 1892) (extrinsic evidence is permissible for contract interpretation)