FACTUAL REBUTTAL & DOCUMENTATION

Case for Our Position

Agency Tribal Nations & Sovereign Rights

Factual rebuttal to legal memorandum with supporting documentation

Introduction

Agency Tribal Nations (ATN) is the legitimate federal interface and governing body for the Mendocino Indian Tribal Government, operating on the foundation of our inherent sovereignty and a specific, modern federal initiative.

The following addresses and corrects inaccuracies contained in a recent legal memorandum, presenting documented facts and legal standing.

1

Entity & Federal Status: Beyond the BIA List

The Claim:

That ATN and the Mendocino Indian Tribal Government are not on the BIA's Federal Register list of recognized tribes.

Our Position:

Federal tribal recognition and authority are not solely or definitively determined by the BIA list. Our status stems from a direct executive branch initiative.

Evidence & Clarification:

  • Agency Tribal Nations is a Department of Health and Human Services (HHS) Executive Branch initiative. It is the designated federal interface for tribal nations in its purview. [Link to Document: Economic Development]
  • The Department of the Interior enacted this specific initiative, not the BIA. The program acknowledges tribes, including ours, for economic development purposes. [Link to Image: HHS/DATN Final Section]
  • Our materials do not "demand" recognition; we operate under authority that was awarded and carried out by the federal government.
2

Historical & Legal Standing of the Mendocino Indian Reservation

The Claim:

The Mendocino Indian Reservation was discontinued in the 1800s.

Our Position:

While the reservation's status was altered, its existence and the land's unique legal history are incontrovertible and form the basis of our continued claim and jurisdiction.

Evidence & Clarification:

3

Sovereignty and the Supremacy of Law

The Claim:

Tribes are "domestic dependent nations" and federal law is supreme.

Our Position:

Tribal governments are sovereign states. This sovereignty is recognized in federal law and creates a government-to-government relationship, not one of subjugation.

Evidence & Clarification:

  • U.S. Federal Code (26 U.S.C. § 7871) explicitly treats tribal governments as states for many statutory purposes, affirming their sovereign standing. [Link: 26 U.S.C. § 7871]
  • The Supremacy Clause applies to conflicts between federal and state law, not to negate the pre-existing sovereignty of tribal nations, which pre-dates the U.S. Constitution.
  • The cited legal case was won on a jurisdictional procedural point (venue), not on the merits of our tribal status or our right to levy taxes and fees. The court did not rule that we lack the authority to impose liens for tribally-owed fees.
4

Cannabis Licensing & Tribal Economies

The Claim:

There is no federal "tribal cannabis license" and tribes cannot authorize activities that violate federal or state law.

Our Position:

Tribal economies are not governed by federal or state cannabis enforcement within the exercise of our sovereign rights. Our Tribal Federal Cannabis Licensing Program is an expression of this sovereignty and a tool for economic development sanctioned under federal initiatives.

Evidence & Clarification:

Conclusion

1

Specific Federal Initiative

Our role as an HHS/executive branch interface with documented federal engagement.

2

Documented Historical Continuity

Verified reservation boundaries and land status from 1908 to present.

3

Established Legal Sovereignty

Recognition as a sovereign state-like entity under U.S. law (26 U.S.C. § 7871).

4

Inherent Economic Rights

The sovereign authority to regulate and license economic activity, including cannabis, within our framework.

Our licensing program is built upon this solid foundation of sovereignty and documented federal engagement, not in circumvention of it.

Document Repository