Myers v. Seneca Niagara Casino
Rachel Myers sued Seneca Niagara Casino, alleging violations of the Family and Medical Leave Act (FMLA) after her termination due to illness. The Casino, an arm of the Seneca Nation of Indians, moved to dismiss based on tribal sovereign immunity, arguing FMLA does not abrogate this immunity and the Nation had not waived it. Plaintiff countered that the Casino's employee manual and a Nation-State Gaming Compact constituted waiver. The Court found no express abrogation by Congress and no clear, unequivocal waiver by the Seneca Nation, distinguishing the cited Compact's limited scope. Consequently, the District Court granted Defendant's motion, dismissing the case for lack of subject matter jurisdiction, also ruling that equitable relief was unavailable.