Page:Lac du Flambeau Band of Lake Superior Chippewa Indians v. Coughlin.pdf/12

Rh (citations omitted). They can also “tax activities on the reservation.” Plains Commerce Bank v. Long Family Land & Cattle Co., 554 U. S. 316, 327 (2008).

It is thus no surprise that Congress has repeatedly characterized tribes as governments. And this Court has long recognized tribes’ governmental status as well. See, e.g., Bay Mills, 572 U. S., at 788–789; Santa Clara Pueblo, 436 U. S., at 57–58. We have done so generally and also in the specific context of tribal sovereign immunity. Tribal sovereign immunity, “we have explained, is ‘a necessary corollary to Indian sovereignty and self-governance.’ ” Bay Mills, 572 U. S., at 788; see also id., at 789 (discussing immunity as an example of tribes’ “governmental powers and attributes”).

Putting the pieces together, our analysis of the question whether the Code abrogates the sovereign immunity of federally recognized tribes is remarkably straightforward. The Code unequivocally abrogates the sovereign immunity of all governments, categorically. Tribes are indisputably governments. Therefore, §106(a) unmistakably abrogates their sovereign immunity too.