LOKEN, Circuit Judge.
Patricia Robertson, a member of the Spirit Lake Tribe in North Dakota, administered the Tribe's Low Income Home Energy Assistance Program, a heating assistance program for low-income families administered by the Tribe and funded by the Department of Health and Human Services. The parties and witnesses refer to this program as "LIHEAP." From 2007 through 2011, Robertson approved applications for heating assistance by her adult daughters, Priscilla...
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