National Farmer’s Union Ins. Co. v. Crow Tribe, 471 U.S. 845, 856-57, 105 S.Ct. 2447, 2454 (1985)
Associated with the Tribal-Exhaustion Doctrine.
Tribal-Exhaustion Doctrine – the general principle that when an Indian tribal court has jurisdiction, the parties must pursue all remedies available under tribal law before turning to non-tribal courts.