act of Congress “terminated the Lake Traverse Reservation, and ... consequently^] the state courts have jurisdiction over conduct on non-Indian lands within the 1867 reservation borders.” See DeCoteau v. Dist. Cnty. Ct. for the Tenth Jud. Dist., 420 U.S. 425, 428, 95 S.Ct. 1082, 43 L.Ed.2d 300 (1975). The territory encompassed by this tribal ordinance included the cities of Sisseton and Peever, South Dakota, and included lands over which the State had exercised jurisdiction since the 1891 allotment of the Tribe's reservation. See id. at 449, 95 S.Ct. 1082. 4 . The circuits are split as to whether a state’s political subdivisions are afforded due process under the Fifth Amendment. Compare In Re Real Est. Title & Settlement Servs. Antitrust Litig., 869 F.2d 760, 765 n. 3 (3d Cir.1989) (<HOLDING>), with City of E. St. Louis v. Cir. Ct. for the
holding school boards are persons within the meaning of the fifth amendment due process clause holding that foreign states are not persons entitled to rights under the due process clause holding municipalities  are not persons within the meaning of the due process clause of the fifth or fourteenth amendments holding that entitlement to benefits is a property interest protected by the due process clause of the fifth amendment to the united states constitution recognizing that corporations are persons within the meaning of the fourteenth amendment