Koi Nation Casino on Hold as Judge Rules Against Windsor Casino Approval

^{Pictured above is a rendering of the proposed Koi Nation casino on the Shiloh Parcel near Windsor, California. (Photo: courtesy of Koi Nation Sonoma)}

US District Court Judge Rita F. Lin ruled in favor of the Federated Indians of Graton Rancheria (FIGR) on September 2, finding that the federal Department of Interior (DOI) erred in approving the Koi Nation’s plan to build a casino on the Shiloh Parcel near Windsor, California.

Judge Lin granted FIGR’s motion for summary judgment on most of the significant issues in the case, finding that FIGR wasn’t adequately consulted on the decision and that DOI improperly applied the restored lands provision of the Indian Gaming Regulatory Act (IGRA).

Judge Cites Improper Approval, Lack of Consultation

In the decision, Judge Lin notes that agency actions such as the DOI decision can only be set aside if they are “arbitrary, capricious, an abuse of discretion, or otherwise not in accordance with law.” Among other issues, Judge Lin noted the decision letter for the project was signed by Bureau of Indian Education Director Tony Dearman, rather than the Secretary of the Interior, who holds the statutory authority.

“There was no urgency that provided the required basis to have Director Dearman, who appears to have had no involvement in the matter prior to when he issued the Record of Decision and Decision Letter, exercise the statutory authority delegated to the Secretary of the Interior,” the decision reads. “Accordingly, the determination to issue the Record of Decision and Decision Letter must be vacated as beyond Director Dearman’s statutory authority.”

Judge Lin notes that this determination alone was enough to invalidate the DOI decision. However, she also found that “the decision was made without adequately consulting FIGR under the National Historic Preservation Act” and that “DOI improperly concluded that Koi had the requisite significant historical connection to the Shiloh Parcel to apply the restored lands provision of IGRA.”

The case now returns to the DOI with instructions to comply with the ruling. The parties are ordered to meet and jointly propose a final judgment that reflects the court’s decision by Sept. 16, 2025.

Tribes Oppose Biden-Era Casino Approvals 

The Koi Nation casino proposal was one of several last-minute approvals for tribal casinos issued in California and Oregon by DOI officials in the final days of the administration of President Joe Biden. FIGR had attempted to prevent that approval by requesting an injunction to delay a format decision on the project, but Judge Lin denied that request in January 2025, just days before the DOI approval was announced.

The decision wasn’t a popular one in California. Several politicians, ranging from local lawmakers to California Governor Gavin Newsom, had come out against the proposal, with Gov. Newsom having written a letter in opposition to the casino to the DOI ahead of their approval. The state of California had also filed its own lawsuit against the DOI over the decision.

Other local tribes also opposed the Koi Nation’s casino ambitions. Along with the FIGR, other Sonoma County tribes including the Lytton Rancheria, Dry Creek Rancheria, and Cloverdale Rancheria had jointly filed a separate lawsuit against the DOI in an attempt to stop the casino from being built. 

Some of these concerns are financial, as the proposed location of the Koi Nation casino would have been about 15 miles from FIGR’s own Graton Resort and Casino, while the Dry Creek Rancheria also operate a casino in Sonoma Valley. 

Tribal leaders also warned that the late approvals by the Biden administration could set a precedent, allowing smaller tribes to build casinos on the ancestral lands of other tribes in the name of economic development.