1981), was a United States Court of Appeals for the Fifth Circuit case that significantly influenced the development of modern Indian Gaming law.

[10] The main issue in the case was whether the State of Florida, as a Public Law 280 state with special rights to exercise limited civil jurisdiction in Indian Country, had the authority to enforce the Florida Bingo Statute on the Seminole Tribe's reservation.

The Tribe argued that the Supreme Court case Bryan v. Itasca County indicates that, although Public Law 280 states have limited civil jurisdiction in Indian Country, they do not have "general regulatory powers.

[16] The lower court enjoined the Sheriff from enforcing the statute, allowing the Seminole Tribe's bingo hall to open in December 1979.

[17] The Sheriff and the State of Florida appealed the District Court's decision to the Fifth Circuit, resulting in the opinion that is the subject of this Article.

[22] As a result, the Fifth Circuit held the Florida Bingo Statute could not be enforced by the Sheriff on the Seminole Tribe's reservation.

[22] Finally, the Fifth Circuit also clarified that the Florida Bingo Statute could not be enforced against either Indians or non-Indians on the reservation.

[25] Scholars often point to the Seminole Tribe's victory in this case as the birth of modern commercial Indian gaming.

[28] Just a year after the Fifth Circuit's Seminole Tribe decision, a similar case called Barona Group v. Duffy arose in California.

[30] Citing to Seminole Tribe and stating that they found it "persuasive," the Ninth Circuit held that California could not enforce its bingo laws on a tribe's reservation because California allowed bingo games in some contexts, meaning its statute was merely regulatory.

[33] Applying a balancing test and reasoning similar to Seminole Tribe, the Court held that the State could not prevent the Cabazon Band of Mission Indians from continuing its bingo operations, even when faced with concerns about organized crime.

[36] The Tribe believed it needed to develop a large and robust revenue source that would decrease their reliance on federal government funding.

[37][38] The Seminole Tribe first turned to opening smokeshops that sold tax-free cigarettes in 1976, generating about $1.5 million in revenue in the first few years.