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Lewis v. Clarke

In a personal injury suit brought against an employee of a tribal casino, who was involved in an auto accident while acting in the scope of his employment, the Supreme Court of Connecticut's judgment granting defendant's to dismiss for lack of subject-matter jurisdiction is reversed where: 1) in a suit brought against a tribal employee in his individual capacity, the employee, not the tribe, is the real party in interest and the tribe's sovereign immunity is not implicated; and 2) an indemnification provision cannot, as a matter of law, extend sovereign immunity to individual employees who would otherwise not fall under its protective cloak.