Here is the complaint in Navajo Nation v. Dept. of Interior (D.D.C.):
Plaintiff Navajo Nation (“Nation”) seeks relief for Defendants’ violations of the Indian Self-Determination and Education Assistance Act, as amended, 25 U.S.C. § 5301 et seq. (“ISDEAA”), and regulations promulgated thereunder, and for Defendants’ breach of a self-determination contract made under the ISDEAA. Under the ISDEAA and governing regulations, Defendants may not decline an Indian tribe’s renewal proposal for a self-determination contract, or contract funding, if it is substantially the same as the prior contract. The Nation submitted a renewal proposal to the Department of the Interior (“Department”) for their contract covering operations of the Navajo Nation Judicial Branch that proposed funding in the amount of $17,055,477 for calendar year (“CY”) 2017. This was the same amount that the Nation sought for CY 2016 and was essentially the same amount that the Nation had previously sought for CY 2014 and CY 2015 ($17,055,517) and which had been approved by operation of law because of Defendants’ failure to decline the Nation’sCY 2014 funding proposal within the 90-day review period established by law. Nonetheless, Defendants partially declined the Nation’s renewal proposal for all funding in excess of $1,429,177.00 for CY 2017. Because Defendants’ action violates the ISDEAA and applicable regulations, the Nation is entitled to declaratory and injunctive relief and damages.