In the case of Iowa Mutual Insurance Co. v. LaPlante et al., 1986, the United States Supreme Court ruled that state and federal courts must abstain from hearing civil cases over which tribal courts have jurisdiction until all tribal remedies have been exhausted. The dispute arose when a non-Indian insurance company sued members of an Indian tribe in federal court for declaratory judgment regarding its liability under an automobile policy after a car accident on a reservation. The defendants had already filed suit in Tribal Court seeking damages from the same accident. The Supreme Court held that principles of comity require that tribal courts have their opportunity to determine their own jurisdiction over claims against Indians arising on reservations before those issues are addressed by other courts.

In the dissenting opinion for Iowa Mutual Insurance Co. v. LaPlante et al., Justice Stevens argued that the majority's decision to require exhaustion of tribal court remedies before proceeding in federal court was inconsistent with prior case law and could lead to unnecessary delays and inefficiencies. He contended that while respect for tribal sovereignty is important, it should not override a plaintiff's right to choose their forum, especially when there are legitimate concerns about impartiality or competency in the tribal courts. Furthermore, he expressed concern that this ruling would create an unfair burden on non-Indian litigants who may be unfamiliar with tribal laws and procedures. In his view, if a federal question is raised or if jurisdictional prerequisites are met, then parties should have immediate access to federal courts without having first to exhaust all possible remedies within a tribe’s judicial system.