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Oklahoma v. Castro-Huerta

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Supreme Court of the United States
Oklahoma v. Castro-Huerta
Term: 2021
Important Dates
Argued: April 27, 2022
Decided: June 29, 2022
Outcome
Reversed and remanded
Vote
5-4
Majority
Brett Kavanaugh • Chief Justice John Roberts • Clarence Thomas • Samuel Alito • Amy Coney Barrett
Dissenting
Neil Gorsuch • Stephen Breyer • Sonia Sotomayor • Elena Kagan

Oklahoma v. Castro-Huerta is a case that was decided by the Supreme Court of the United States on June 29, 2022, during the court's October 2021-2022 term. The case was argued before the court on April 27, 2022.

In a 5-4 ruling, the court reversed the decision of the Oklahoma Court of Criminal Appeals and remanded the case for further proceedings, holding that "the federal government and the state have concurrent jurisdiction to prosecute crimes committed by non-Indians against Indians in Indian country."[1] Justice Brett Kavanaugh delivered the majority opinion of the court. Justice Neil Gorsuch filed a dissenting opinion, joined by Justices Stephen Breyer, Sonia Sotomayor, and Elena Kagan. Click here for more information about the ruling.


HIGHLIGHTS
  • The issue: The case concerned state authority in Indian country and the scope of the U.S. Supreme Court's ruling in the case McGirt v. Oklahoma (2020). Click here to learn more about the case's background.
  • The questions presented:
    "1. Whether a State has authority to prosecute non-Indians who commit crimes against Indians in Indian country.
    "2. Whether McGirt v. Oklahoma, 140 S. Ct. 2452 (2020), should be overruled."[2]
  • The outcome: The U.S. Supreme Court reversed the decision of the Oklahoma Court of Criminal Appeals and remanded the case for further proceedings.


    • The case came on a writ of certiorari to the Oklahoma Court of Criminal Appeals. To review the lower court's opinion, click here.[3]

    Timeline

    The following timeline details key events in this case:

    • June 29, 2022: The U.S. Supreme Court reversed the decision of the Oklahoma Court of Criminal Appeals and remanded the case for further proceedings.
    • April 27, 2022: The U.S. Supreme Court heard oral argument.
    • January 21, 2022: The U.S. Supreme Court agreed to hear the case.
    • September 17, 2021: The State of Oklahoma appealed to the U.S. Supreme Court.
    • April 29, 2021: The Oklahoma Court of Criminal Appeals vacated the state district court's judgment and sentence and remanded the case with instructions to dismiss.


    Background

    Victor Manuel Castro-Huerta was convicted of child neglect in Tulsa County District Court in 2015 and was sentenced to 35 years imprisonment. Castro-Huerta's stepdaughter, whom he was convicted of neglecting, is a member of the Eastern Band of Cherokee Indians. Castro-Huerta is not a member. On appeal, the Oklahoma Court of Criminal Appeals vacated his conviction because the crime occurred in Indian country, holding that the U.S. Supreme Court's ruling in the case McGirt v. Oklahoma (2020) covers crimes committed by any individual in Indian country.[2][3][4]

    On September 17, 2021, the State of Oklahoma appealed to the U.S. Supreme Court, asking the justices to consider whether the state can prosecute this crime and to consider overturning its ruling in McGirt v. Oklahoma (2020). On January 21, 2022, the court agreed to hear the case during its October 2021-2022 term, but limited review to the first question only.

    McGirt v. Oklahoma (2020)

    See also: McGirt v. Oklahoma (2020)

    Case background

    In 1997, a jury in Wagoner County District Court found Jimcy McGirt guilty of one count of first-degree rape by instrumentation, one count of lewd molestation, and one count of forcible sodomy. He was sentenced to 500 years in prison for the first two counts and life in prison without parole for the third count. McGirt appealed to the Oklahoma Court of Criminal Appeals, the state's court of last resort for criminal matters. The court denied McGirt's petition for review.[5]

    On April 17, 2019, McGirt petitioned the U.S. Supreme Court for a writ of certiorari. In his petition, McGirt argued the Wagoner County District Court lacked jurisdiction to hear his case because: (1) McGirt is a member of the Seminole/Creek Nations of Oklahoma, (2) the crimes for which he was convicted allegedly occurred in Indian country, and (3) the crimes "are enumerated within the Indian Major Crimes Act."[6]

    Timeline

    The following timeline details key events in this case:

    • July 9, 2020: The U.S. Supreme Court reversed the Oklahoma Court of Criminal Appeals' (OCCA) decision.
    • May 11, 2020: The court heard oral argument.
    • April 3, 2020: The court postponed its April sitting. Oral arguments in McGirt v. Oklahoma were initially scheduled for April 21, 2020.
    • December 13, 2019: The U.S. Supreme Court agreed to hear the case.
    • April 17, 2019: Jimcy McGirt, the petitioner, appealed to the U.S. Supreme Court.
    • February 25, 2019: The OCCA affirmed the Wagoner County District Court's order denying McGirt's petition for post-conviction relief.

    Outcome

    In a 5-4 opinion, the court reversed the judgment of the Oklahoma Court of Criminal Appeals, holding that under the Indian Major Crimes Act, lands reserved for the Creek Nation in eastern Oklahoma constituted Indian country.[7]

    Justice Neil Gorsuch delivered the opinion of the court, joined by Justices Ruth Bader Ginsburg, Stephen Breyer, Sonia Sotomayor, and Elena Kagan. Chief Justice John Roberts filed a dissenting opinion, joined by Justices Samuel Alito and Brett Kavanaugh, and joined in part by Justice Clarence Thomas. Justice Thomas also filed a separate dissenting opinion.

    Indian country

    18 U.S.C § 1151 defines Indian country as:[8]

    “

    (a) all land within the limits of any Indian reservation under the jurisdiction of the United States Government, notwithstanding the issuance of any patent, and, including rights-of-way running through the reservation,

    (b) all dependent Indian communities within the borders of the United States whether within the original or subsequently acquired territory thereof, and whether within or without the limits of a state, and

    (c) all Indian allotments, the Indian titles to which have not been extinguished, including rights-of-way running through the same.[9]

    		”

    Questions presented

    The petitioner presented the following questions to the court:[2]

    Questions presented:
    “ 1. Whether a State has authority to prosecute non-Indians who commit crimes against Indians in Indian country.
    2. Whether McGirt v. Oklahoma, 140 S. Ct. 2452 (2020), should be overruled.[9]     		”


    The U.S. Supreme Court limited review in the case to Question 1.[10]

    Oral argument

    In its order granting review in the case, the U.S. Supreme Court said the case would be argued during the April argument session.[10]

    Audio

    Audio of oral argument:[11]



    Transcript

    Transcript of oral argument:[12]

    Outcome

    In a 5-4 ruling, the court reversed the decision of the Oklahoma Court of Criminal Appeals and remanded the case for further proceedings, holding that "the federal government and the state have concurrent jurisdiction to prosecute crimes committed by non-Indians against Indians in Indian country."[1] Justice Brett Kavanaugh delivered the majority opinion of the court. Justice Neil Gorsuch filed a dissenting opinion, joined by Justices Stephen Breyer, Sonia Sotomayor, and Elena Kagan.


    Opinion

    In the court's majority opinion, Justice Brett Kavanaugh wrote:[1]

    “ This case presents a jurisdictional question about the prosecution of crimes committed by non-Indians against Indians in Indian country: Under current federal law, does the Federal Government have exclusive jurisdiction to prosecute those crimes? Or do the Federal Government and the State have concurrent jurisdiction to prosecute those crimes? We conclude that the Federal Government and the State have concurrent jurisdiction to prosecute crimes committed by non-Indians against Indians in Indian country.[9] ”
    —Justice Brett Kavanaugh

    Dissenting opinion

    Justice Neil Gorsuch filed a dissenting opinion, joined by Justices Stephen Breyer, Sonia Sotomayor, and Elena Kagan.

    In his dissent, Justice Gorsuch wrote:[1]

    “ In 1831, Georgia arrested Samuel Worcester, a white missionary, for preaching to the Cherokee on tribal lands without a license. Really, the prosecution was a show of force—an attempt by the State to demonstrate its authority over tribal lands. Speaking for this Court, Chief Justice Marshall refused to endorse Georgia’s ploy because the State enjoyed no lawful right to govern the territory of a separate sovereign. See Worcester v. Georgia, 6 Pet. 515, 561 (1832). The Court’s decision was deeply unpopular, and both Georgia and President Jackson flouted it. But in time, Worcester came to be recognized as one of this Court’s finer hours. The decision established a foundational rule that would persist for over 200 years: Native American Tribes retain their sovereignty unless and until Congress ordains otherwise. Worcester proved that, even in the “[c]ourts of the conqueror,” the rule of law meant something. Johnson’s Lessee v. McIntosh, 8 Wheat. 543, 588 (1823).


    Where this Court once stood firm, today it wilts. After the Cherokee’s exile to what became Oklahoma, the federal government promised the Tribe that it would remain forever free from interference by state authorities. Only the Tribe or the federal government could punish crimes by or against tribal members on tribal lands. At various points in its history, Oklahoma has chafed at this limitation. Now, the State seeks to claim for itself the power to try crimes by non-Indians against tribal members within the Cherokee Reservation. Where our predecessors refused to participate in one State’s unlawful power grab at the expense of the Cherokee, today’s Court accedes to another’s. Respectfully, I dissent.[9]

    		”
    —Justice Neil Gorsuch

    Text of the opinion

    Read the full opinion here.

    October term 2021-2022

    See also: Supreme Court cases, October term 2021-2022

    The Supreme Court began hearing cases for the term on October 4, 2021. The court's yearly term begins on the first Monday in October and lasts until the first Monday in October the following year. The court generally releases the majority of its decisions in mid-June.[13]

    The court agreed to hear 68 cases during its 2021-2022 term.[14] Four cases were dismissed and one case was removed from the argument calendar.[15]

    The court issued decisions in 66 cases during its 2021-2022 term. Three cases were decided without argument. Between 2007 and 2021, SCOTUS released opinions in 1,128 cases, averaging 75 cases per year.


    See also

    External links

    Footnotes

    1. ↑ 1.0 1.1 1.2 1.3 U.S. Supreme Court, Oklahoma v. Castro-Huerta, decided June 29, 2022
    2. ↑ 2.0 2.1 2.2 U.S. Supreme Court, "Oklahoma v. Castro-Huerta: PETITION FOR A WRIT OF CERTIORARI," filed September 17, 2021
    3. ↑ 3.0 3.1 Oklahoma Court of Criminal Appeals, Castro-Huerta v. Oklahoma, decided April 29, 2021
    4. ↑ SCOTUSblog, "Justices will review scope of McGirt decision, but won’t consider whether to overturn it," January 21, 2022
    5. ↑ Oklahoma Court of Criminal Appeals, Jimcy McGirt v. Oklahoma, decided February 25, 2019
    6. ↑ Supreme Court of the United States, "Petition for a writ of certiorari," accessed December 16, 2019
    7. ↑ Supreme Court of the United States, McGirt v. Oklahoma, decided July 9, 2020
    8. ↑ Legal Information Institute, "18 U.S. Code § 1151.Indian country defined," accessed December 16, 2019
    9. ↑ 9.0 9.1 9.2 9.3 Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
    10. ↑ 10.0 10.1 U.S. Supreme Court, "(ORDER LIST: 595 U.S.)," January 21, 2022
    11. ↑ Supreme Court of the United States, "Oral Argument - Audio," argued April 27, 2022
    12. ↑ Supreme Court of the United States, "Oral Argument - Transcript," argued April 27, 2022
    13. ↑ SupremeCourt.gov, "The Supreme Court at Work: The Term and Caseload," accessed February 4, 2021
    14. ↑ Consolidated cases are counted as one case for purposes of this number.
    15. ↑ U.S. Supreme Court, "Order List: 593 U.S.," May 17, 2021
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