
2240, 144 L.Ed.2d 636 (1999) (noting that sovereign immunity protects the financial integrity of States, many of which "could have been forced into insolvency but for their immunity from private suits for money damages"). Immunity of the Casino directly protects the sovereign Tribe's treasury, which is one of the historic purposes of sovereign immunity in general. With the Tribe owning and operating the Casino, there is no question that these economic and other advantages inure to the benefit of the Tribe. The question is not whether the activity may be characterized as a business, which is irrelevant under Kiowa, but whether the entity acts as an arm of the tribe so that its activities are properly deemed to be those of the tribe. Fantasy Springs Casino, 71 Cal.App.4th 632, 642, 84 Cal.Rptr.2d 65 (1999) (recognizing sovereign immunity of for-profit corporation formed by a tribe to operate the tribe's casino). Ct., 88 Cal.App.4th 384, 388-89, 105 Cal.Rptr.2d 773 (2001) (holding that off-reservation casino owned and operated by tribe was arm of the tribe, and therefore was entitled to sovereign immunity) Trudgeon v.

2006) (holding that Blackfeet Tribe's sovereign immunity extends to Blackfeet Housing Authority) Redding Rancheria v.Super.

When the tribe establishes an entity to conduct certain activities, the entity is immune if it functions as an arm of the tribe.

This immunity extends to business activities of the tribe, not merely to governmental activities. Although the Supreme Court has expressed limited enthusiasm for tribal sovereign immunity, the doctrine is firmly ensconced in our law until Congress chooses to modify it.
