In our November issue, we reported that the U.S. Supreme Court had granted review of a Second Circuit Court of Appeals decision which had held that two New York counties were barred by the principle of tribal sovereign immunity from proceeding with a foreclosure action against the Oneida Indian Nation for unpaid county taxes, even though the taxes were properly assessed, leaving the counties with a right but no remedy. Madison County v. Oneida Indian Nation, Dkt. Nos. 05-6408, 06-5168 & 06-5515 (2d Cir. Apr. 27, 2010), cert granted, 562 U.S. __ (No. 10-72) (Oct. 12, 2011). After review was granted, the Oneida Indian Nation submitted a letter advising that the Nation had passed a declaration waiving its sovereign immunity, and the counties submitted a responsive letter, questioning the validity, scope and permanence of the waiver, to which the Nation responded. Now, the Supreme Court has vacated its judgment granting review and remanded the case to the Court of Appeals, for it to consider the effect of the letters and the original ruling on sovereign immunity, and if necessary to address other issues in the case. Madison County v. Oneida Indian Nation, 562 U.S. ____ (2011).