This article discusses the on-going issue of tribal versus federal judicial power. While tribal courts have been recognized as an important aspect of tribal sovereignty, federal precedent has diluted tribal authority. This dilution of authority is evident by the restriction on jurisdiction given to the tribal courts by the federal government. The author explores this issue using the case of Burrell v. Armijo. She contends that this Tenth Circuit case demonstrates the continued undermining of tribal jurisdiction and that the general rule for federal courts to give great deference to tribal courts was not properly applied, leading to continued weakening of tribal jurisdiction and tribal sovereignty by the federal judiciary.
Garcia, Erin. "Burrell v. Armijo: The Role of Comity in Federal Court Review of Tribal Court Judgments." Tribal Law Journal 10, 1 (2010). https://digitalrepository.unm.edu/tlj/vol10/iss1/2