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A state court can generally assert jurisdiction over a civil suit arising out of Indian Country1 where state civil jurisdiction 1) is not preempted by federal law and 2) does not infringe upon tribal rights of self-government.2 The Supreme Court has declared that the infringement prong of this infringement-preemption test requires an analysis of both state and tribal interests: state courts can protect a state's interest up to the point where state authority affects the "right of reservation Indians to make their own laws and be ruled by them."' State courts have little difficulty ascertaining the state's interest in a given controversy, but they have shown less aptitude for determining and upholding tribal interests. Indeed, they often act as if their authority were supreme, as if they existed in a world without Indian tribes.4 The "no law" cases illustrate how courts have struggled to properly characterize tribal rights of self-government without the aid of a principled framework for defining tribal interests.5 In these cases, courts must determine whether state court jurisdic-

A World without Tribes? Tribal Rights of Self-Government and the Enforcement of State Court Orders in Indian Country