SHOSHONE-BANNOCK TRIBES OF THE FORT HALL RESERVATION v. U.S. DEPARTMENT OF THE INTERIOR
The Ninth Circuit denied petitions for panel and en banc rehearing, upholding the district court's summary judgment that the Bureau of Land Management lacked authority to conduct a land exchange involving Fort Hall Reservation lands. The court held that a specific 1900 statute governing these ceded lands prohibits disposal via the Federal Land Policy and Management Act because the earlier law's plain text bars such transfers.