# They may be instituted by a private citizen on behalf of the Government, Ex rel.
United States ex rel. Gerald Mayo v. Satan and His Staff | Missouri ex rel. Gaines v. Canada | Ex rel | Da'Rel Scott |
In United States ex rel. Chunie v. Ringrose (1986), the United States Court of Appeals for the Ninth Circuit considered the trespass and conversion claims of Chumash tribe (joined by the federal government) over the ownership of the Channel Islands of California (and the channel beds surrounding the Santa Cruz and Santa Rosa islands) in California.