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Administrative Law Keyed to Koch
Equal Employment Opportunity Commission v. Karuk Tribe Housing Authority
Citation:
260 F.3d 1071 (2001)Facts
The Karuk Tribe Housing Authority owns 100 low-income housing units on tribal trust land in Northern California. The Housing Authority, established through tribal ordinance, functions as an arm of the tribal government and receives funding under the Native American Housing Assistance and Self-Determination Act. Robert Grant, a 53-year-old enrolled member of the Tribe, worked as a maintenance supervisor for the Housing Authority for almost seven years until his termination in November 1997. Grant challenged his firing through internal tribal administrative proceedings, which were rejected by both the Board of Commissioners and the Tribal Council. In February 1998, Grant filed an age discrimination complaint with the EEOC. The EEOC opened an investigation and issued a subpoena to the Tribe seeking employment records. The Tribe refused to comply, asserting that the ADEA does not apply to Indian tribes and that the Tribe enjoys sovereign immunity from EEOC investigation.
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