United States DC Circuit

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Patchak v. Salazar, 09-5324

In an action to prevent the Secretary of the Interior from holding land in trust for an Indian tribe in Michigan, the dismissal of the action is affirmed where the terms of the Quiet Title Act did not cover plaintiff's suit, and his action therefore fell within the general waiver of sovereign immunity set forth in section 702 of the Administrative Procedure Act.

Appellate Information

  • Decided 01/21/2011
  • Published 01/21/2011


  • A. Raymond Randolph


  • United States DC Circuit


  • For Appellant:
  • John J. Bursch, Aaron P. Avila

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