Oklahoma v. Castro-Huerta

(Slip Opinion) OCTOBER TERM, 2021 1 Syllabus NOTE: Where it is feasible, a syllabus (headnote) will be released, as is being done in connection with this case, at the time the opinion is issued. The syllabus constitutes no part of the opinion of the Court but has been prepared by the Reporter of Decisions for the convenience of the reader. See United States v. Detroit Timber & Lumber Co., 200 U. S. 321, 337. SUPREME COURT OF THE UNITED STATES Syllabus OKLAHOMA v. CASTRO-HUERTA CERTIORARI TO THE COURT OF CRIMINAL APPEALS OF OKLAHOMA No. 21–429. Argued April 27, 2022—Decided June 29, 2022 In 2015, respondent Victor Manuel Castro-Huerta was charged by the State of Oklahoma for child neglect. Castro-Huerta was convicted in state court and sentenced to 35 years of imprisonment. While Castro- Huerta’s state-court appeal was pending, this Court decided McGirt v. Oklahoma, 591 U. S. ___. There, the Court held that the Creek Na- tion’s reservation in eastern Oklahoma had never been properly dises- tablished and therefore remained “Indian country.” Id., at ___. In light of McGirt, the eastern part of Oklahoma, including Tulsa, is rec- ognized as Indian country. Following this development, Castro- Huerta argued that the Federal Government had exclusive jurisdiction to prosecute him (a non-Indian) for a crime committed against his step- daughter (a Cherokee Indian) in Tulsa (Indian country), and that the State therefore lacked jurisdiction to prosecute him. The Oklahoma Court of Criminal Appeals agreed and vacated his conviction. This Court granted certiorari to determine the extent of a State’s jurisdic- tion to prosecute crimes committed by non-Indians against Indians in Indian country. Held: The Federal Government and the State have concurrent jurisdic- tion to prosecute crimes committed by non-Indians against Indians in Indian country. Pp. 4–25. (a) The jurisdictional dispute in this case arises because Oklahoma’s territory includes Indian country. In the early Republic, the Federal Government sometimes treated Indian country as separate from state territory. See Worcester v. Georgia, 6 Pet. 515. But that view has long since been abandoned. Organized Village of Kake v. Egan, 369 U. S. 60, 72. And the Court has specifically held that States have jurisdic- tion to prosecute crimes committed by non-Indians against non-Indi- ans in Indian country. United States v. McBratney, 104 U. S. 621; see 2 OKLAHOMA v. CASTRO-HUERTA Syllabus also Draper v. United States, 164 U. S. 240, 244–247. Accordingly, States have jurisdiction to prosecute crimes committed in Indian coun- try unless preempted. Pp. 4–6. (b) Under Court precedent, a State’s jurisdiction in Indian country may be preempted by federal law under ordinary principles of federal preemption, or when the exercise of state jurisdiction would unlaw- fully infringe on tribal self-government. Neither serves to preempt state jurisdiction in this case. Pp. 6–20. (1) Castro-Huerta points to two federal laws—the General Crimes Act and Public Law 280—that, in his view, preempt Oklahoma’s au- thority to prosecute crimes committed by non-Indians against Indians in Indian country. Neither statute, however, preempts the State’s ju- risdiction. …

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