The Ninth Circuit held last month that IGRA does not require the National Indian Gaming Commission (NIGC) to determine whether a gaming ordinance contemplates a gaming operation on “Indian lands” prior to (1) approving an ordinance that does not specify a site for the casino or (2) the tribe’s licensure and construction of a casino. In essence, the Ninth Circuit determined that enforcement of the Indian lands requirement of IGRA may only be undertaken by the NIGC and states – not private citizens like the North County Community Alliance (“Alliance”).