Gila River Indian Community v. Lyon

Issue: (1) Whether, under Federal Rule of Civil Procedure 19(b), courts may adjudicate and compromise legal rights in land to which the United States holds title without the United States" participation in the litigation; and (2) whether, in light of this Court"s recent decision in United States v. Jicarilla Apache Nation, No. 10-382 (June 13, 2011), litigation compromising the United States" title in land can proceed in the United States" absence as long as an Indian tribe is a party to the litigation.