immunity”). Tribal immunity is not synonymous with a State’s Eleventh Amendment immunity, and parallels between the two are of limited utility. See, e.g., Three Affiliated Tribes, 476 U.S. at 890, 106 S.Ct. 2306 (“Of course, because of the peculiar ‘quasi-sovereign’ status of the Indian tribes, the Tribe’s immunity is not congruent with that which the Federal Government, or the States, enjoy.”). Importantly, Spates can waive their Eleventh Amendment immunity through litigation conduct that would not effect a waiver of tribal sovereign immunity. For example, a State’s filing of a claim may waive its Eleventh Amendment immunity to counterclaims that arise from the same transaction or occurrence, at least in the bankruptcy context. See In re Lazar, 237 F.3d 967, 978 (9th Cir. 2001) (<HOLDING>). A tribe, in contrast, does not waive its
holding that the eleventh amendment does not bar a bankruptcy court from issuing a money judgment against a state under the bankruptcy code holding that a state waives eleventh amendment immunity to claims that arise from the same transaction or occurrence holding that when state voluntarily submits a claim in a bankruptcy proceeding the state waives its sovereign immunity holding that state waived its eleventh amendment immunity by filing proofs of claim in bankruptcy proceedings holding that when a state  files a proof of claim in a bankruptcy proceeding the state waives its eleventh amendment immunity with regard to the bankruptcy estates claims that arise from the same transaction or occurrence as the states claim