United States v. Jackson, No. 11-3718 (8th Cir. 2012)
Annotate this CaseDefendant, an Indian, was charged with brutally assaulting the victim in a town within the original boundaries of the Red Lake Indian Reservation. The district court denied defendant's motion to dismiss the indictment, concluding as a matter of law that the alleged assault occurred within the boundaries of the Reservation and therefore in "Indian country." The court concluded that the district court made its Indian country ruling on an inadequate record and remanded with directions to permit defendant to withdraw his guilty plea. Therefore, the court need not address defendant's additional contention that his sentence was substantively unreasonable.
Court Description: Criminal Case - Indian Country. District court's determination as a matter of law that offense occurred on privately owned land but within Indian country was based on a record consisting of little more than the statute's text and was prejudicial error. Section 1 and Section 5 of the 1905 Act do not provide clear and plain evidence of congressional intent to diminish the Red Lake Reservation's boundaries by the grant of Reservation acreage to expand the railroad's terminal facilities, but the district court did not consider whether diminishment extended to land beyond the minimum needed for a railroad's right of way. Thus the district court erred in precluding Jackson's Indian country defense and he should be granted an opportunity to withdraw his guilty plea consistent with his conditional plea agreement.
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