Davisson v. Colville Confederated Tribes

10 Am. Tribal Law 403
CourtColville Confederated Court of Appeals
DecidedApril 30, 2012
DocketNo. AP08-001
StatusPublished

This text of 10 Am. Tribal Law 403 (Davisson v. Colville Confederated Tribes) is published on Counsel Stack Legal Research, covering Colville Confederated Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Davisson v. Colville Confederated Tribes, 10 Am. Tribal Law 403 (Colo. 2012).

Opinion

NELSON, J.2

Appeal to determine whether provisions of the Domestic Violence Code violate provisions of ICRA and CTCRA by imposing enhanced sentencing and requiring the defendant to prove self defense by a preponderance of the evidence. We affirm in part and reverse in part.

PROCEDURAL HISTORY

On June 3, 2004, the Business Council of the Confederated Tribes of the Colville Reservation (hereinafter CBC) amended the Domestic Violence Code, CTC 5-5 et seq., to enhance sentencing for crimes involving domestic violence. The CBC also added a provision that, should self-defense be claimed, the defendant has the burden of proving self-defense by a preponderance of the evidence, rather than the prosecution having to prove the absence of self-defense by proof beyond a reasonable doubt.

The appellants are numerous defendants charged with crimes involving domestic violence who contend their rights were violated under the Indian Civil Rights Act, 25 USC 1302, (hereinafter ICRA) and the Colville Tribal Civil Rights Act, CTC 1-5 (hereinafter CTCRA) by the enhanced sentencing requirements. Appellants also contend that requiring a defendant to prove self-defense by a preponderance of the evidence for crimes involving domestic violence violates ICRA and CTCRA in that the tribal prosecutor should have the burden to prove a lack of self-defense beyond a reasonable doubt. They make these arguments on the basis of the trial court’s interlocutory order denying defendant’s motion to accept proposed jury instructions which supported their position.

Grounds for an interlocutory appeal may be found where “the issue presented involve a controlling issue of law as to which there is substantial ground for difference of opinion and that an intermediate appeal from the decision may materially advance the ultimate termination of the outcome:” COACR 7-A(b). This appeal meets the criteria for review.

JURISDICTION

This court has personal and subject matter jurisdiction of these cases pursuant to the Constitution of the Colville Confederated Tribes3 and the Colville Tribal Code4. [407]*407Also see Colville Confederated Tribes v. Stockwest, CV86-624, 21 ILR 6075 (1984) and National Farmers Union Ins. Co. v. Crow Tribe, 471 U.S. 845, 12 ILR 1035 (1985). The defendants are Native American and the criminal acts alleged herein took place within the exterior boundaries of the Reservation.

STANDARD OF REVIEW

The material facts of these cases are not disputed for the purpose of this appeal. The issues are entirely those of law. Accordingly, the standard of review' is de novo. CCT v. Naff, 2 CCAR 50, 2 CTCR 08, 22 ILR 6032 (1995), Wiley et al. v. CCT, 2 CCAR 60, 2 CTCR 09, 22 ILR 6059 (1995).

STATEMENT OF RELEVANT FACTS

The cases before us are similar only in that they involved alleged crimes involving domestic violence. They do, however, present identical issues of law for this court to determine. In order to put the issues in perspective and for purposes of illustration, we set forth the facts alleged in Davisson.

Connie Davisson was charged with willfully striking or otherwise inflicting bodily injury by scratching her former boyfriend on his nose and cheek on October 25, 2004. (Battery) CTC 3-1-4. She is also charged in a separate count of biting him on his chest at the same date and time. (Battery) CTC 3-1-4. She is further charged with entering or remaining in a building without permission with the purpose of committing the above referenced crimes. (Burglary) CTC 3-1-41. And finally, she is charged with possessing a controlled substance. (Prohibited Aets-Possession) CTC 3-1-180.

The first three counts are alleged crimes involving domestic violence. Domestic Violence is defined as ,. the occurrence of one or more of the following acts by a family or household but does not include acts of self-defense or culturally appropriate discipline of a child.” CTC 5-5-3(d). These include acts “Attempting to cause or causing physical, mental, or emotional harm to another family or household member” CTC 5—5—3(1) and acts “Attempting to commit or committing any criminal offense under Colville Tribal law against another family or household member.” CTC 5-5-3(4). A household member includes “persons who are dating or have dated.” CTC 5-5-3(g)(3). It is alleged that Connie Davisson assaulted her former boyfriend.

The complaint charging Ms. Davisson with these erimes noted on its face that the battery and burglary counts wore subject to enhanced penalties. The complaint labeled the crimes as “Domestic Violence Battery” and “Domestic Violence Burglary.”

The prosecution of Ms. Davisson was without complication until the parties submitted proposed jury instructions. The prosecution/appellee’s proposed jury instructions were standard instructions for the crimes of battery and burglary. Additional instructions directed the jurors to determine: 1) whether the defendant committed a crime beyond a reasonable doubt involving domestic violence, and 2) whether, by a preponderance of the evidence, the acts of committing the erime were made by another family or household member. Proposed instructions were also included that provided for the defendant to prove such by a preponderance of the evidence.

The defendant/appellants’s proposed jury instructions took a different track. Their proposed instructions contend the amendments to the Domestic Violence Code resulted in the establishment of the new crimes of Domestic Violence Battery and Domestic Violence Burglary. They [408]*408also included instructions requiring the prosecution to disprove self defense beyond a reasonable doubt for all criminal offenses charged. The Trial Court rejected this view and denied the motion to accept the proposed instructions.

The defendants/appellants filed this appeal.

ISSUES

1. Whether the Due Process and Equal Protection rights given criminal defendants under ICRA and the Tribal Civil Rights Act are violated by the provisions of the Domestic Violence Act that require those claiming self-defense to establish it by a preponderance of the evidence;

2. Whether the Due Process and Equal Protection rights given criminal defendants under ICRA and the Tribal Civil Rights Act are violated by the provisions of the Domestic Violence Code that allows the prosecution to establish that a crime is a crime of domestic violence by a preponderance of the evidence rather than by evidence beyond a reasonable doubt; and

3. Whether the provisions of the Domestic Violence Code that require those criminal defendants claiming self-defense to establish it by a preponderance of the evidence violate the rights given them under ICRA and the Tribal Civil Rights Act to not be compelled to testify against themselves?

DUE PROCESS AND EQUAL PROTECTION

The Colville Confederated Tribes enacted the Civil Rights Act (CTCRA) of the Confederated Tribes of the Colville Reservation which provides that the Tribes shall not “(d)eny any person within its jurisdiction the equal protection of its laws or deprive any person of liberty or property without due process of law.” CTC 5—2(h).

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Bluebook (online)
10 Am. Tribal Law 403, Counsel Stack Legal Research, https://law.counselstack.com/opinion/davisson-v-colville-confederated-tribes-colvctapp-2012.