In the case of National Farmers Union Insurance Cos. et al. v. Crow Tribe of Indians et al., 1984, the U.S Supreme Court ruled that federal courts must stay proceedings if a tribal court has already asserted jurisdiction over a matter until all available remedies have been exhausted in tribal court, including appeals within the tribe's own judicial system before it can be reviewed by federal courts. The dispute arose when an accident occurred on Indian reservation land involving non-tribal members and their insurance company sued in Federal District Court for declaratory relief against both parties involved in the accident as well as against Tribal Court officials to prevent them from exercising jurisdiction over this off-reservation incident. The Supreme Court held that exhaustion of tribal remedies is required because it promotes Congress' policy goals towards self-determination and self-governance among tribes, respects their sovereignty, and allows for development of a substantial record while also providing other relevant factual findings related to issues concerning reservation affairs.

In the dissenting opinion for National Farmers Union Insurance Cos. et al. v. Crow Tribe of Indians et al., Justice Stevens argued that the majority's decision to allow federal courts to review tribal court decisions before exhausting all possible tribal remedies was a departure from established principles of judicial restraint and comity towards Native American tribes, which have their own sovereign legal systems. He contended that this ruling undermines the authority and autonomy of tribal courts by allowing litigants to circumvent these bodies in favor of more favorable rulings in federal court, thereby weakening self-governance efforts among Native American communities. Furthermore, he expressed concern over how this precedent might be used in future cases involving disputes between non-tribal entities and tribes or their members on reservation lands.