Navajo Nation v. Arviso

This case concerns the dismissal of a forcible detainer action against an occupant of a business site property. We vacate the decision and remand for further proceedings.

I

The relevant facts are as follows. Bess and Arturo Arviso were the lessees to a twenty-five year business site lease with the Navajo Nation (Nation). The lease authorized the lessees’ use of Navajo Nation trust land to operate a gas station in Crownpoint. The lease, which did not include a renewal or renegotiation clause, expired in October 2001. Bess Arviso died in 1996 and Arturo Arviso died in 2002 shortly after the lease…