Lac du Flambeau Band v. Coughlin

When the Lac du Flambeau Band sought bankruptcy protection, it invoked tribal sovereign immunity to prevent the lender from proceeding in federal bankruptcy court, arguing that its status as a federally recognized tribe gave it the same immunity shield available to states. The Court applied the Bankruptcy Code's abrogation language, holding that Congress had clearly intended the immunity waiver to encompass tribes as 'governmental units,' making the tribe's sovereign immunity claim unavailable as a defense. Because the Bankruptcy Code's text treated tribal governments the same way it treated state governments for purposes of the immunity abrogation, the tribe had to proceed through bankruptcy like any other debtor and could not use immunity to block the process.