The competition is a tuneup for the Academy Awards on Sunday, where Leo is Oscar-nominated.
Leo gave a whoop as she took the stage to collect her prize for "Frozen River," which got its start a year ago at the Sundance Film Festival, where it won the top dramatic honor. She stars as a destitute mother who stumbles into the immigrant-smuggling business with a Mohawk Indian woman along the U.S.-Canada border.
"You are my people. You know you are my people," Leo told the independent-cinema crowd at the awards luncheon in a tent along the Santa Monica beach. "'Frozen River' is a truly independent film."
For more on the subject, see The Best Indian Movies.