Judge Blocks Koi Nation Casino Approval, Orders Federal Re-Do

The US Department of the Interior's (DOI) decision to grant the Koi Nation land-into-trust status was overturned by a federal judge, putting the future of the casino project in Sonoma County, California, in jeopardy.

In the center of California's wine country, close to the town of Windsor, the Nation has long planned to construct its $600 million Shiloh Casino.  The Graton Rancheria tribe (FIGR), which runs the Graton Hotel & Casino in Rohnert Park, only 15 miles from the planned Koi Nation location, opposes its goals.

Among other reasons, FIGR contested the Koi Nation's ancestral links to the land and said the DOI did not conduct a thorough investigation into the tribe's past.

FIGR Problems

The DOI consented to put the Shiloh property into federal trust for the Koi Nation in January 2025, a prerequisite that permits tribes to construct casinos in accordance with federal law.  Concurrently, the DOI authorized gambling on the property, enabling the tribe to proceed with building.

FIGR filed a lawsuit, claiming that the government had improperly expedited the Koi Nation's application and disregarded its own traditional links to the region.  The State of California filed a lawsuit, claiming that the procedure circumvented the governor's authority to approve new casinos.

Accepted by the Incorrect Official

Judge Rita F. Lin of the Northern District of California gave FIGR a partial success on Wednesday when she remanded the case for additional proceedings and vacated the DOI's decision to transfer the Shiloh Parcel into federal trust for the Koi Nation.

Lin supported the challengers on a number of important issues, such as the fact that the final clearance was given by a director of the Bureau of Indian Affairs (BIA), who the court found lacked the legal power to make the decision.  Only the Secretary of the Interior, an official confirmed by the Senate, is authorized by federal law to make such judgments.

Weak Bonds

To be eligible for gambling on land, tribes must demonstrate a strong historical link, according to the Indian gambling Regulatory Act (IGRA).  The judge determined that the Koi Nation's use of historical census data, trade routes, and seasonal labor in the region was insufficient to establish that the Shiloh location was actually a part of their traditional homeland.

“…[E]ven assuming it could be reasonably inferred that Koi tribal members occasionally worked as seasonal farm laborers on the Shiloh Parcel, seasonal labor on the land is insufficient to establish the requisite significant historical connection to the land. Such a connection requires evidence that ‘the parcel was of historic, economic, and cultural significance’ to Koi,” Lin wrote.

"In sum, the record does not support DOI’s conclusion that Koi established a significant historical connection to the Shiloh Parcel, such that IGRA authorized gaming on the land under the restored lands exception,” she concluded.

As required by preservation regulations, the court also determined that the DOI had not adequately consulted the FIGR regarding cultural and historical consequences.

Judge Lin dismissed additional environmental review concerns at the same time, stating that the government had sufficiently examined groundwater, traffic, and wildfire threats.

The order suspends the Koi Nation's plans for a casino resort indefinitely and requires the DOI to reevaluate the land-into-trust decision, possibly restart discussions, and reexamine whether IGRA's restored-lands exception fits. This procedure might take years.