The following excerpt is from Cachil Dehe Band of Wintun Indians v. California, 536 F.3d 1034 (9th Cir. 2008):
7 The parties do not dispute that the absent tribes enjoy sovereign immunity. See Santa Clara Pueblo v. Martinez, 436 U.S. 49, 58, 98 S.Ct. 1670, 56 L.Ed.2d 106 (1978). Accordingly, because they have not consented to suit, they cannot be joined in this action.
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