# Petition — Fort Belknap Indian Community v. District Court of the Twelfth Judicial District

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## Record

- **Collection:** Supreme Court brief
- **Document type:** Petition
- **Published:** January 1, 1977
- **Citation:** 430 U.S. 928

## Text

FILFD ,

JAN 3 1977

MICHAEL RODAK, JR., CLERK

IN THE
Supreme Court of the United States

OcToBER TERM, 1976

No.7 we-Q919 a

THE Fort BELKNAP INDIAN COMMUNITY OF THE Fort
BELKNAP INDIAN RESERVATION, Montana, Peti-
tioner, ¥,

TxHeE District Court oF THE TWELFTH JUDICIAL Dis-
TRICT OF THE STATE OF MONTANA, IN AND FOr THE
CouNTY OF BLAINE, AND THE HONORABLE BERNARD
W. Tuomas, District Court Jupar, Respondents.

PETITION FOR A WRIT OF CERTIORARI TO THE
SUPREME COURT OF THE STATE OF MONTANA

—_-_—_— —-—~-——
Pui Roy
FRANK LAMEBULL

P.O. Box 849
Browning, Montana 59417

DANTEL H. IsrRaEn
NATIVE AMERICAN RicHTs Funp
1506 Broadway
Boulder, Colorado 80302

Counsel for Petitioner

Press or Byron S. ADAMS PrInTING, INc., WasutncTon, D. C.

a eat PP I igi a A a

TABLE OF CONTENTS

Page
NR hs ie i ddd aeubunenee 1
PE ng a ee eek caer cay 2
I UII 5 ek idnon 0nedecdecnccssecsees 2
SY CINE igo cc cca see audseae eabekeeeee 2
STATEMENT OF THE CASE ... 2... ccc cccccccccccccccees 5
Reasons For Grantinc THe WRIT .............0005- 8

I. This Case Presents an Unresolved Issue of
Great Importance to the 180 American Indian
Tribes Which Have Accepted the Indian Re-
IN BON. 5.6 05 605 900050506060 asas ee 8

II. The Political and Business Development Provi-
sions of the Indian Reorganization Act are
Separate and Distinct. ..............ceeeees 12

III. The Montana Construction of the Indian Re-
organization Act is Fundamentally Inconsis-
tent with Concepts of Tribal Sovereign Immu-

nity Long Recognized by This Court ......... 16
SES ic asdenacdocdcdadacuecaucedananccdeunes 19
NS in 660i Kon KA Shh ae nindinededdweeweunset la

TABLE OF AUTHORITIES

CasEs:

Bryan v. Itasca County, .... U.S. , 48 L.Ed.2d
710, 96 S.Ct. 2102 (1976) eh Sade athe Una ah eae 12, 16

Cherokee Nation v. State of Oklahoma, 461 F.2d 674
ed ie ee inden ieee ee le ak 10

Edelman v. Jordan, 415 U.S, 651 (1974) ............ 9,18

Fisher v. District Court, 424 U.S. 382 (1976) ..8, 12, 14, 20
Fitzpatrick v. Bitzer, .... U.S. ...., 49 L.Eid.2d 614,
ee: Se ED cc. oncuxiosedcdtadandecsnwes 9

il Table of Authorities Continued

Page

Great Northern Life Insurance Co v. Read, 322 U.S.
GT CEBGBD cc cccccvcaccccccccscevurcscsccase 9, 17,18
Haile v. Saunooke, 246 F.2d 293 (4th Cir. 1957), cert.
denied, 355 U.S. 893 (1957) .......cceececccees
Hamilton v. Nakai, 453 F.2d 152 (9th Cir. 1972) .... 10
Keifer v. Reconstruction Finance Corp., 306 U.S, 381

CBIED). cccccccnssccccnsscccvsesesccccseecssess 18
Kennerly v. District Court, 400 U.S. 423 (1971) .... 20
Land v, Dollar, 330 U.S. 731 (1947) ..........00 eee 9,17
Larson v. Domestic and Foreign Commerce Corp., 337

I, GE GRID ncccscccccsnnencdesccceseosses 9,17

Madruga v. Superior Court, 346 U.S, 556, (1954) .... 8

Martinez v. Southern Ute Tribe, 374 P.2d 691 (Colo.
CIEE nc pvccccvsdsesitocesvestvscseedsceoncees 11,15

Maryland Casualty Co. v. Citizens National Bank of
West Hollywood, 361 F.2d 517 (5th Cir, 1966),

cert. denied 385 U.S. 918 (1967) ..........eeeee- 15
Mesealero Apache Tribe v. Jones, 411 U.S, 145 (1973) 138
Monaco v. Mississippi, 292 U.S. 313 (19384) ......... 9,18
Morgan v. Colorado River Indian Tribe, 443 P.2d

421 (Ariz. 1968) .....ccccccccccccccccccccseces 10

Namekagon Development Co. v. Bois Forte Reserva-
tion Housing Authority, 395 F. Supp. 23 (D. Minn.

1974), aff’d 517 F.2d 508 (8th Cir. 1975) ........ 11,14
New York v. United States, 326 U.S, 572 (1946).... 8,9
Ohio v. Helvering, 292 U.S. 360 (1934) ...........46- 9
Parden v. Terminal Ry. of the Alabama State Docks

Dept., 387 U.S. 184 (1964) ......... eee eee reer 9
Turner v. United. States, 248 U.S. 354 (1919) ...... 17

Twin Cities Chippewa Tribal Council v. Minnesota
Chippewa Tribe, 870 F.2d 529 (8th Cir, 1967) .. 10

United States v. Mazurie, 419 U.S. 544 (1975) ...... 14, 19

United States v. Shaw, 309 U.S. 495 (1940) .......... 17

United States v. United States Fidelity & Guaranty
Ce.. 300 UE. GES CIDA) .ncccccccccevces 9, 16, 17,18

Williams v. Lee, 358 U.S. 217 (1959) .......-..0. eee 14

Table of Authorities Continued iii

P
STATUTES AND CopEs: _
11 Stat. 657, Treaty of October 17, 1855 ............ 5
18 Stat. 28, Act of April 15, 1874 ................... 5
25 Stat. 113, Act of May 1, 1888 .................... 5
48 Stat. 984, 25 U.S.C. § 461, the Indian Reorganization
Ee oe ee rere Pere e oy rrr er 2, 4, 13
82 Stat. 77, 25 U.S.C. § 1302, the Indian Civil Rights
MN 6 0c4 eeu heeaesn ta cade Mak eues be chateeies sce 19
86 Stat. 1176, 28 U.S.C. § 2409a; Act of October 25
Ree aa ee Oy "18
88 Stat. 77, 25 U.S.C. $1451, et seq., the Indian Fi-
memo Bot of ISTE 2... cc ccccccescccccccnesves 12,15

88 Stat. 2203, 25 U.S.C. $450, et seq., the Indian Self-
Determination and Edueation Assistance Act of

Sy 65d deen duahs kee Ube rabeeeaeee cnn deees 12, 15, 16
et oe ee 20
EE a 15, 16
iP Wein: GET 6640 bee cnccedscacvciacds 2, 3, 6, 8, 13
ee Ny EE oo Gon acayneee ao Obs ccbancacilan 2,8

INTER!OR OPINIONS:

Solicitor’s Opinion M-36119, 61 ID. 8 (Feb. 14,1952) .. 10
Solicitor’s Opinion M-36515, 65 1.D. 483 (Nov. 20,1958) 10

Solicitor’s Op‘nion, 55 I.D. 14, (1934) ............... 14
Solicitor’s Opinion, 69 I.D. 483 (1958) ............. 12,13
LecisLaTive History:

S.Rep. 3645, 73d Cong., 2d Sess. (1934) ..........5. 10

iv Table of Authorities Continued

Page
Oruer AUTHORITIES:
Fort Belknap Indian Community Corporate Charter.. 4,5

Comment, Tribal Self-Government in the Indian Re-
organization Act of 1934, 70 Mich.L.Rev. 955,
ty | rrr re 11

1972 U.S. Code Congressional & Administrative News
GOGE nccccusvvessescensenee neuen 18

Executive Order of July 5, 1873, I Kapp. 855, 856 (2d
ION 5

IN THE
Supreme Court of the United States

OcToBer TERM, 1976

No. 76-

Tue Fort BeLKNAP INDIAN COMMUNITY OF THE Fort
BELKNAP INDIAN RESERVATION, Montana, Peti-

tioner, -

Tue District Court oF THE TWELFTH JUDICIAL Dts-
TRICT OF THE STATE OF MONTANA, IN AND FOr THE
CounTY OF BLAINE, AND THE HONORABLE BERNARD
W. Tuomas, District Court Jupace, Respondents.

PETITION FOR A WRIT OF CERTIORARI TO THE
SUPREME COURT OF THE STATE OF MONTANA

The Fort Belknap Indian Community of the Tort
Belknap Indian Reservation in Montana petitions for

a writ of certiorari to review the judgment of the Su-

preme Court of the State of Montana.

OPINIONS BELOW

The judgment of the Montana Supreme Court (App.
p. la) is reported at 554 P.2d 1115 (Mont. 1976). The
state district court’s order (App. p. 2a) is not reported.

2

JURISDICTION

The judgment of the Supreme Court of the State of
Montana was entered on October 7, 1976. Jurisdiction
of this court is invoked under 28 U.S.C. § 1257(3).

QUESTION PRESENTED

Did Congress in the Indian Reorganization Act
the Act of June 18, 1934, 48 Stat. 984, 25 U.S.C. § 461
et seq.. Waive the immunity from suit of the Fort Bel-
knap Indian Community in a tort aetion involving the
conduct of a tribal police officer ?

STATUTES INVOLVED
INDIAN REORGANIZATION ACT

Section 16 of the Indian Reorganization A
codified at 25 U.S.C. § 476 provides: , i: *

Organization of Indian tribes; constitution and
by laws; special election

Any Indian tribe, or tribes, residing on the
same reservation, shall have the right to organize
for its common welfare, and may adopt an ap-
propriate constitution and bylaws, which shall
heeome effective when ratified by a majority vote
of the adult members of the tribe, or of the adult
Indians residing on such reservation, as the ease
may be, at a special election authorized and ealled
by the Secretary of the Interior under such rules
and regulations as he may preseribe. Such consti-
tution and by-laws, when ratified as aforesaid and
approved by the Secretary of the Interior, shall
he revocable by an election open to the same voters

and conducted in the same manner as hereinabove -

previded. Amendments to the constitution and
by-laws may be ratified and approved by the See-
retary in the same manner as the original consti-
tution and by-laws.

3

In addition to all powers vested in any Indian
tribe or tribal council by existing law, the con-
stitution adopted by said tribe shall also vest in
such tribe or its tribal council the following rights
and powers: To employ legal counsel, the choice of
counsel and fixing of fees to be subject to the ap-
proval of the Secretary of the Interior; to pre-
vent the sale, disposition, lease, or encumbrance
of tribal lands, interests in lands, or other tribal
assets without the consent of the tribe; and to
negotiate with the Federal, State, and local Gov-
ernments. The Secretary of the Interior shall ad-
vise such tribe or its tribal council of all appropria-
tion estimates or Federal projects for the benetit
of the tribe prior to the submission of such esti-
mates to the Bureau of the Budget and the Con-

gress.

Section 17 of the Indian Reorganization Act, codi-
fied at 25 U.S.C. § 477, provides:

The Secretary of the Interior may, upon petition
by at least one-third of the adult Indians, issue a
charter of incorporation to such tribe: provided,
That such charter shall not become operative until
ratified at a special election by a majority vote of
the adult Indians living on the reservation. Such
charter may convey to the incorporated tribe the
power to purchase, take by gift, or bequest, or
otherwise, own, hold, manage, operate, and dispose
of property of every description, real and personal,
including the power to purchase restricted Indian
lands and to issue in exchange therefor interests in
corporate property, and such further powers as
may be incidental to the conduct of corporate bus-
iness, not inconsistent with law, but no authority
shall be granted to sell, mortgage, or lease for a
period exceeding ten years any of the land included
in the limits of the reservation. Any charter so is-
sued shall not be revoked or surrendered except

by Act of Congress.

4

Fort BELKNAP INDIAN COMMUNITY CORPORATE CHARTER

Whereas, the Fort Belknap Indian Community
of the Fort Belknap Reservation in Montana con-
stitutes a recognized Indian Community organized
under a constitution and by-laws ratified by the
Gros Ventre and Assiniboine Tribes of the Fort
Belknap Indian Reservation on October 19, 1935,
and approved by the Secretary of the Interior on
December 13, 1935, pursuant to Section 16 of the
Act of June 18, 1994 (48 Stat. 984), as amended
by the Act of June 15, 1935 (49 Stat. 378); and

Whereas, more than one-third of the adult Ind-
ians on the Fort Belknap Indian Reservation who
are members of the Gros Ventre and Assiniboine
Tribes have petitioned that a charter of incorpora-
tion be granted to such community, subject to rati-
fication by vote of said Indians living on said re-
servation;

Now, therefore, 1, Charles West, Acting See-
retary of the Interior, by virtue of the authority
conferred upon me by the said Act of June 18, 1934
(48 Stat. 984), do hereby issue and submit this
charter of ineorporation to the Fort Belknap Ind-
ian Community of the Fort Belknap Reservation
to be effective from and after such time as it may
be ratified by a majority vote of the adu't Indians
living on the reservation, at an election in which
at least thirty percent of the eligible voters vote.

1. Corporate Existence. In order to further the
economie development of the Fort Belknap Indian
Community of the Fort Belknap Reservation in
Montana by conferring wpon the said community
certain corporate rights, powers, privileges and im-
munities; to secure for the members of the Com-
munity an assured economie Independence; and to
provide for the proper exercise by the Community
of various functions heretofore performed by the
Department of the Interior, the aforesaid com-

re, T, Charles West, Acting Seeretary of the
Interior, by virtue of the authority conferred upon me by
the said Act of June 18, 1934 (48 Stat. 984), do hereby
issue and submit this charter of incorporation to the Fort
Belknap Indian Community of the Fort Belknap Reserva-

tion to be effective from and after such time as it may be

ratified hy a majority vote of the adult Indians living on
the reservation, at an election in which at least thirty per
cent of the eligible voters vote.

1. Corporate Existence. In order to further the economic
development of the Fort Belknap Indian Community of the
Fort Belknap Reservation in Montana by conferring upon
the said community certain corporate rights, powers, privi-
leges and immunities; to secure for the members of the
Community an assured economic independence; and to pro-
vide for the proper exercise by the Communities of various
functions heretofore performed by the Department of the
Interior, the aforesaid community is hereby chartered as
a body politie and corporate of the United States of
America, under the corporate name ‘The Fort Belknap
Indian Community. ”’

2. Perpetual Succession. The Fort Belknap Indian Com-
munity shall, as a Federal corporation, have perpetual sue-
cession,

3. Membership [as Amended]. The Fort Belknap Indian
Community shall be a membership corporation. Its mem-
bers shall consist of all persons now or hereafter members
of the Community, as provided by its duly ratified and ap-
proved Constitution and By-laws, as amended.

4, Membership [as Amended]. The Fort Belknap Com-
munity Council consisting of six (6) members of the Gros

ae ee. ee ee DAL el Milly % o :

i Ase Pinil

bin

{
:
;

7a

Ventre Tribe of Indians and six (6) members ef the Assini-
boine Tribe of Indians of the Fort Belkn: p Indian Reser-
vation, elected by all the electors of the Community, shall
exercise all the corporate powers hereinafter enumerated.

5. Corporate Powers. The Community, subject to any
restrictions contained in the Constitution and laws of ‘the
United States, or in the Constitution and By-laws of the
said community, or in this Charter, shall have the follow-

ing corporate powers:

(a) To adopt, use, and alter at its pleasure a corpo-
rate seal.

(b) To purchase, take by gift, bequest, or otherwise,
own, hold, manage, operate, and dispose of property of
every description, real and personal, subject to the fol-
lowing limitations:

(1) No sale or mortgage may be made by the Com-
munity of any land, or interest in land, now or
hereafter held by the Community.

(2) No leases, permits (which terms shall not inelude
land assignments to members of the Community)
or timber sale contracts covering any land or in-
terests in land now or hereafter held by the Com-
munity within the boundaries of the Fort Belknap
Reservation shall be made by the Community for
a longer term than ten years, and all such leases,
permits, or contracts must be approved by the See-
retary of the Interior or by his duly authorized
representative; but oil and gas leases, mineral
leases, or any leases requiring substantial im-
provements of the land may be made for longer
periods when authorizcd by law.

(3) No action shall be taken by or in behalf of the
Community which conflicts with regulations au-

Sa

thorized by Section 6 of the Act of June 18, 1934,
or in any way operates to destroy or injure the
Community grazing lands, timber, or other nat-
ural resources of the Fort Belknap Reservation.

(c) To issue interests in corporate property in ex-
change for restricted Indian land.

(d) To borrow money from the Indian Credit Fund
in accordance with the terms of Section 10 of the Act of
June 18, 1934, (48 Stat. 984), or from any other govern-
mental agency, or from any member or association of mem-
bers of the Community, and to use such funds directly for
productive tribal enterprises, or to loan money thus bor-
rowed to individual members or associations of members
of the Community; Provided, That the amount of indebt-
edness to which the Community may subject itself, aside
from loans from the Indian Credit Fund, shall not exeeed
$2,500, except with the express approval of the Secretary
of the Interior.

(e) To engage in any business that will further the
economic well-being of the members of the Community or
to undertake any activity of any nature whatever, not in-
consistent with law or with any provisions of this Charter.

(f) To make and perform contracts and agreements of
every description, not inconsistent with law or with any
provisions of this Charter, with any person, association, or
corporation, with any municipality or any county, or with
the United States or the State of Montana, including agree-
ments with the State of Montana for the rendition of pub-
lic services: Provided, That any contracts, other than con-
tracts with the United States, involving payment of money
by the corporation totalling in excess of $2,000 during any
one fiscal year shall be subject to the approval of the Sec-

retary of the Interior or his duly authorized representa-
tive.

ee ee Tet te er eee

9a

(¢) To pledge or assign chattels or future income due
or to become due to the Community under any notes, leases,
or other contracts, or from any other source, whether or
not such notes, leases, or contracts are in existence at the
time: Provided, That such agreement of assignment, other
than agreements with the United States, shall not extend
more than ten years from the date of execution and shall
not cover more than one half the income from any source:
And provided further, That any such agreement shall be
subject to the approval of the Secretary of the Interior or
his duly authorized representative.

(h) To deposit corporate funds, from whatever source
derived, in any national or state bank to the extent that
such funds are insured by the Federal Deposit Insurance
Corporation, or secured by a surety bond, or other security,
approved by the Secretary of the Interior; or to deposit
such funds in the Postal Savings Bank or with a bonded
Disbursing Officer of the United States to the credit of the
community.

(i) To sue and to be sued in courts of competent juris-
diction within the United States; but the grant or exercise
of such power to sue and to be sued shall not be deemed a
consent by the Community or by the United States to the
levy of any judgment, lien or attachment upon the property
of the Community other than income or chattels specially
pledged or assigned.

(j) To exercise such further incidental powers not in-
consistent with law, as may be necessary to the conduct of
corporate business.

6. Termination of Supervisory Powers. Upon the re-
quest of the Communcity Council of the Fort Belknap In-
dian Community for the termination of any supervisory
power reserved to the Secretary of the Interior under See-
tions 5(b) (2), 5(d), 5(f), 5(@), 5(h), and Section 8 of this
Charter, the Secretary of the Interior, if he deems it wise

10a

and expedient to do so, shall thereupon submit the question
of such termination or grant for ratification by the Com-
munity. If the Secretary of the Interior shall approve such
termination it shall be effective upon ratification by a ma-
jority vote of the adult members of the Community resid-
ing on the reservation, at an election in which at least 30
per cent of the eligible voters vote. If the Secretary shall
disapprove such termination, or fail to approve or disap-
prove it within 90 days after its receipt, it may then be
submitted by the Secretary or by the Community Council
to popular referendum of the adult members of the Com-
munity actually living within the reservation, and if ap-
proved by two-thirds of the eligible voters shall be effective.

7. Tribal Rights and Claims. (a) Property rights and
present and future claims of the Gros Ventre and Assini-
boine Tribes of Indians who have entered into a partner-
ship to form the Fort Belknap Indian Community for the
management of their joint affairs, shall not be in any way
impaired by anything contained in this Charter, or in the
Constitution and By-Laws of the Fort Belknap Indian
Community.

(b) Nothing in this Charter, or in the Constitution and
By-Laws of the Fort Belknap Indian Community shall con-
stitute a release or waiver or shall in any way impair any
present or future claims of the Gros Ventre Tribe of In-
dians of the Fort Belknap Indian Reservation, or of the
Assiniboine Tribe of Indians of the Fort Belknap Indian
Reservation, against the United States, against each other,
or against any other tribe or tribes of Indians.

(c) The tribal unallotted lands of the Fort Belknap
Indian Reservation are hereby vested in the Fort Belknap
Indian Community, subject however to the restrictions con-
tained in Section 7, paragraph (b) of this Charter.

(d) The Gros Ventre members of the Community
Council and the Assiniboine members of the Community
Council shall each have sole and exclusive jurisdiction over
all matters concerning the exclusive property rights and

lla

present and future claims of each of their said tribes, and
shall transact the exclusive business policy and administra-
tive affairs of their respective tribes, and shall exercise
their said several powers to the same extent and for the
same purposes as exercised by each of said tribal councils
prior to the ratification of the Fort Belknap Indian Com-
munity Constitution and By-laws and the granting of this
Charter.

(e) That the administration of moneys borrowed by
the Fort Belknap Indian Community and reloaned to mem-
bers of the community or associations of such members
shall be under the jurisdiction of two sub-committees of the
council, one consisting only of Gros Ventre councilmen to
administer all loans to Gros Ventre Indians, and one con-
sisting only of Assiniboine councilmen to administer all
loans to Assiniboine Indians. The amounts allocated to the
two sub-committees shall be equal except in so far as dem-
onstrated differences in population or need warrant any
other equitable division.

8. Corporate Dividends. The Community may issue to
each of its members a nontransferable certificate of mem-
bership evidencing the equal share of each member in the
assets of the Community and may distribute per capita,
among the recognized members of the Community, all in-
come of the Community over and above sums necessary to
defray corporate obligations to members of the Community
or to other persons and over and above all sums which may
be devoted to the establishment of a reserve fund, the con-
struction of public works, the costs of public enterprises,
the expenses of the Community government, the needs of
charity, or other corporate purposes. No such distribution
of profits in any one year amounting to a distribution of
more than one half of the aecrued surplus, shall be made
without the approval of the Secretary of the Interior.

9. Corporate Accounts. The officers of the Community
shall maintain accurate and complete public accounts of

12a

the financial affairs of the Community, which shall clearly
show all credits, debts, pledges, and assignments, and shall
furnish an annual balance sheet and report of the financial
affairs of the Community to the Commissioner of Indian
Affairs. The Secretary Treasurer of the Fort Belknap
Indian Community shall pay out money only in accord-
ance with the orders and resolutions of the Community
Council, and no disbursements shall be made without the
signature or approval of the Seeretary-Treasurer. The
books of the Seeretary-Treasurer shall be audited at the
direction of the Community Council or of the Commissioner
of Indian Affairs, and shall be open to inspection by mem-
bers of the Community or duly authorized representatives
of the Secretary of the Interior at all reasonable times.

10. Amendments. This Charter shall not be revoked or
surrendered except by Act of Congress, but amendments
may be proposed by resolutions of the Community Council
which if approved by the Secretary of the Interior, to be
effective shall be ratified by a majority vote of the adult
members living on the reservation at a popular referendum
in which at least 30 per cent of the eligible voters vote.

11. Ratification. This Charter shall be effective from and
after the date of its ratification by a majority vote of the
adult members of the Fort Belknap Indian Community
living on the Fort Belknap Reservation, provided at least
30 per cent of the eligible voters shall vote; such ratifiea-
tion to be formally certified by the Superintendent of the
Belknap Indian Community.

Submitted by the Acting Secretary of the Interior for
ratification by the Fort Belknap Indian Community in a
popular referendum to be held on August 25, 1937.

Cuaries West
Acting Secretary of the Interior

Washington, D. C., July 29, 1937.
[Seal]

13a

CERTIFICATION

Pursuant to Section 17 of the Act of June 18 1934 (48
Stat. 984), this Charter, issued on July 29, 1937 by the
Acting Secretary of the Interior to the Fort Belknap In-
dian Community of the Fort Belknap Reservation, was
duly submitted for ratification to the adult Indians living
on the Reservation and was on August 25, 1937, duly carried
» Fleas of 277 for and 158 against, in an election in
a Sew eanaied percent of those entitled to vote cast

Ricuarp Kina,
President of the Fort Belknap
Indian Community.

F’. W. Boyp
Superintendent of Fort Belknap A gency.

---

Source: Frix Law Library, https://www.frixlaw.com/law-library/documents/brief%3Amicro_IA40385004_1105%3A1. Public record. Not legal advice.