What is the test for habeas relief under the Indian Civil Rights Act?

Though narrow, this claim for relief is firmly established. See Boe v. Fort Belknap Indian Cmty., 642 F.2d 276, 278-79 (9th Cir. 1981) (describing 25 U.S.C. 1303 as "[t]he only avenue available to a party who seeks relief in the federal courts for an alleged violation of the ICRA"). Of course, recognizing the "well-established federal policy of furthering Indian self-government," Santa Clara Pueblo, 436 U.S. at 62 (internal quotation marks omitted), we "should not rush to create causes of action" that would intrude upon tribes' inherent sovereignty, id. at 72 n.32. But we are not asked to "create causes of action" in this case; we are asked to apply the only law by which Indians may vindicate their ICRA rightsthe congressionally granted right to petition for habeas relief.