Part I sets out the historical backdrop, while Part II outlines the doctrinal context. 8 This Note attempts to ameliorate that tension by advocating a labor movement that builds worker power under the protections of tribal, rather than federal, law.

7 This tension is especially acute in the ideological context of the modern labor movement, which casts unionism as rooted in values of progressivism and social justice. Unionizing workers, often members of non-Native minority groups, feel disenfranchised in their workplaces, while Native governments perceive intervention into their internal affairs as threatening their inherent sovereignty 6 - sovereignty that has been weakened through congressional action and Supreme Court decisions. Labor organizing in tribal enterprises 5 uncovers a seemingly intractable tension between two classes of power-building institutions: unions and tribes. But to many tribal governments, this invocation of a federal statute is an affront to the inherent sovereignty of Native nations. The protections of federal labor law have been crucial to building worker power in private-sector enterprises. 1 Many of these (primarily non-Native 2) workers have invoked the protections of the National Labor Relations Act 3 (NLRA). Since 1990, employees of businesses owned and operated by Native nations have increasingly sought to amplify their voices in the workplace through union representation.

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