Walters, Sarah

Sarah leverages her experience as a former litigator to provide counsel on laws, policies, regulations and legislation moving through federal and state policy arenas. She represents clients before Congress and federal agencies on a range of matters, including administrative law, regulatory compliance, Indian affairs, and tribal gaming. Sarah is an experienced liaison between Indian tribes and businesses, facilitating transactions between both parties and advocating on behalf of her clients during contract negotiations and complex deals.

Before joining the firm, Sarah spent four years at the Department of the Interior, most recently serving as an attorney in the Division of Indian Affairs within the Interior’s Solicitor’s Office. While there, she provided legal advice to offices within Indian Affairs and across the department, and prepared litigation documents and briefs to defend the department’s decisions in Administrative Procedure Act (APA) lawsuits. She previously served as both chief of staff and senior counselor to the assistant secretary of Indian Affairs. Prior, Sarah served at the National Indian Gaming Commission as a staff attorney and counselor to the chair, where she led regulatory reviews that resulted in the enactment of new policies. At both Interior and the Commission, Sarah was involved in each aspect of the regulatory process, from initial discussion drafts through publication of a final rule.

Earlier in her career, Sarah served as a trial attorney for the Department of Justice, Commercial Litigation Branch. Sarah draws on her deep understanding of the APA and regulatory process to take advantage of opportunities and to protect clients from shifting policy landscapes at the federal and state levels.

Representative Matters
News & Events
  • Cheyenne River Sioux Tribe Member
  • The Tacy Foundation, Board of Directors
  • Native American Bar Association, Mentor
Publications & Presentations
  • Procedures Announced for Tribes to Apply for 2.5 GHz Spectrum

    We have previously issued several alerts regarding the ability of eligible tribal entities to apply for certain airwave licenses that can be used for wireless internet access and other services. Our alerts can be found here, here and here. The window for applying for this spectrum opens on Feb. 3, 2020, and closes on August 3, 2020. The FCC has now released procedures for applying.

    The FCC urges potential applicants to familiarize themselves with the general rules governing operation in the 2.5 GHz band and “strongly encourages” applicants to conduct due diligence to determine whether they will be able to provide services using the spectrum. This is a critical step as the failure to deploy a network using the spectrum within four or five years will result in cancellation of the license. The FCC identified the following non-exclusive list of factors that applicants should consider: (1) determine how much spectrum is available in the areas in which they wish to provide service; (2) assess where transmission equipment could be sited and the process for acquiring and/or leasing such sites; (3) determine technical requirements, including infrastructure and other network equipment needs; (4) consider nearby wireless services that must be protected from interference; (5) assess system financing and partnership arrangements and system administration and management; and (6) consider network and backhaul needs.

    Applications will only be accepted during the filing window and they must be filed electronically through the agency’s Universal Licensing System. The FCC includes some step-by-step filing instructions here. There is no filing fee but standard filing forms must be used. Applicants must file a separate application for each separate tribal area and there is no limit to the number of applications an eligible tribe or tribally owned entity may file.

    The application must include necessary exhibits and information to demonstrate that it meets all four eligibility criteria: (1) the applicant is a federally recognized tribe or Alaska Native Village, or consortium of eligible tribes, or an entity owned and controlled by an eligible tribe; (2) the area for which the applicant seeks a license is an eligible tribal land; (3) the tribal land is rural (The FCC has a mapping tool to help identify eligible tribes and areas.); and (4) the applicant maintains a local presence for each tribal land that is the subject to the application. If for some reason a tribe cannot technically meet one of these requirements, it must request a waiver as part of the application. An applicant must also have a current FCC Form 602 Ownership Form on file when it files its application.

    The FCC’s Wireless Bureau is available to provide individualized assistance.

    Please feel free to contact the authors, Michael Pryor, at, or Sarah Walters, at, if you have any questions.

  • Priority Filing Deadline Set for Tribes’ Access to Spectrum
    Brownstein Client Alert, December 3, 2019

  • FCC To Assess Tribal Engagement Process

    Brownstein Client Alert, October 29, 2019

  • Government Urges Tribes to Apply for Free Access to Spectrum
    Brownstein Client Alert, September 24, 2019

  • FCC Sets Aside Airwaves for Rural Tribal Areas
    Brownstein Client Alert, July 22, 2019

  • Don’t block tribes from online gaming market
    Author, Indian Country Today, June 18, 2019

  • The Challenge of Increasing Broadband Access on Tribal Lands
    Brownstein Client Alert, December 3, 2018

  • J.D., 2007, University of Pennsylvania Law School
  • B.A., 2004, University of Maryland
  • District of Columbia
  • Maryland, (inactive)