Stanley Longo v. Seminole Indian Casino-Immokalee, 813 F.3d 1348

Stanley Longo sued Seminole Indian Casino-Immokalee alleging gender discrimination and retaliation under Title VII and the Florida Civil Rights Act.
The Casino is owned and operated by the Seminole Tribe of Florida, a tribe listed in the Bureau of Indian Affairs’ federally recognized tribes list.
The district court dismissed Longo’s suit on the ground that the Tribe is a federally recognized Indian tribe entitled to sovereign immunity.
No congressional abrogation of immunity or tribal waiver was claimed or shown by Longo.
The Eleventh Circuit reviewed the dismissal de novo and took judicial notice of the Federal Register listing recognizing the Tribe.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the Tribe is subject to suit for Longo’s employment discrimination claims	Longo asserted statutory claims against the Casino under Title VII and Florida law	The Tribe claimed sovereign immunity as a federally recognized Indian tribe, barring suit	The court held the Tribe is federally recognized and immune; dismissal affirmed
Whether sanctions are appropriate for a frivolous appeal	Longo implicitly argued appeal was permissible	Tribe sought sanctions under Fed. R. App. P. 38 and 28 U.S.C. § 1927 as frivolous	The court denied sanctions in its discretion but warned future similar appeals likely frivolous

Contour Spa at the Hard Rock, Inc. v. Seminole Tribe of Fla., 692 F.3d 1200 (11th Cir. 2012) (standard of review for sovereign immunity dismissal)
Kiowa Tribe of Okla. v. Mfg. Techs., Inc., 523 U.S. 751 (1998) (tribal sovereign immunity principle)
LaPier v. McCormick, 986 F.2d 303 (9th Cir. 1993) (relying on BIA list as best source for federally acknowledged tribes)
United States v. Holliday, 70 U.S. 407 (1865) (courts defer to the political branches’ recognition of tribes)