March 26, 2019 ‘Deemed Allowed’ Claims Can Be Binding in Subsequent Litigation, Circuit Says A failure to distinguish between res judicata and collateral estoppel turned out to be costly. 6th Circuit , 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 ,