Tahoe-Sierra Preservation Council, Inc. v. Tahoe Regional Planning Agency

How later courts describe this case

• holding that oral instructions which require a jury to find mitigating circumstances unanimously to be reversible error
• holding that where tribal court resolves a question of federal law, the federal court should review the decision de novo
• pro se litigant should be afforded every reasonable opportunity to demonstrate that he or she has a valid claim
• “a single instruction to a jury may not be judged in artificial isolation but must be viewed in the context of the overall charge”
• “dismissal with prejudice is a harsh remedy to be used only in extreme situations ...”
• question of tribal court jurisdiction is a federal question