March 1, 2019 Creating a Split, Sixth Circuit Holds: No Waiver of Immunity for Indian Tribes A divided panel of the Sixth Circuit holds that Section 106 does not waive sovereign immunity for Indian tribes. 6th Circuit , November 15, 2016 Sixth Circuit Bars Bankruptcy Courts from Enforcing Constitutional Rights in Chapter 9 Barring a city in chapter 9 from turning off the water violates Section 904, Sixth Circuit rules. 6th Circuit ,