Fort McDowell Yavapai Nation v. Haynes

4 Am. Tribal Law 217
CourtFort McDowell Supreme Court
DecidedSeptember 19, 2003
DocketNo. TR-2002-144
StatusPublished

This text of 4 Am. Tribal Law 217 (Fort McDowell Yavapai Nation v. Haynes) is published on Counsel Stack Legal Research, covering Fort McDowell Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Fort McDowell Yavapai Nation v. Haynes, 4 Am. Tribal Law 217 (ftmcdowell 2003).

Opinions

[218]*218OPINION

Justice TSOSIE,

joined by Justice LUl-FRANK, delivered the opinion of the Court.

STATEMENT

This case concerns an appeal by the Fort McDowell Yavapai Nation from the post-disposition of a criminal case. The issue is whether the Trial Court had the authority to order a criminal defendant’s fees and costs to be deducted from his per capita allocation, given the substantive changes made to preexisting policies on this issue by the Fort McDowell Yavapai Council. This Court has jurisdiction to hear this appeal pursuant to Section 4-32(B), Fort McDowell Law and Order Code, which provides appellate jurisdiction over any final judgment issued by the courts of the Fort McDowell Yavapai Nation.

On October 22, 2002, Darold. Haynes was arrested for driving while intoxicated and driving with a suspended license. On December 13, 2002, a judgment of guilt was entered against him on both charges. Defendant was fined a total of $600, sentenced to 15 days in jail (from December 13 to December 28, 2002) and ordered to pay incarceration costs and fees of SI,050. On January 26, 2003, a Trial Court ordered was entered extending the time for Haynes to pay his fines until February 14, 2003. On February 3, 2003, Iho Trial Court entered an Order Withholding Per Capita. This Order was addressed to the Fort McDowell Finance Officer. It provided that:

THEREFORE, IT IS ORDERED Finance is authorized to deduct the amount of $2,250.00 from Darold Haynesf] Per Capita and distribute said amount to the above listed payees [the Tribal Court and the Nation’s , Police department] pursuant to the financial agreements by Tribal Finance, Tribal Court and Tribal Police.

On February 4, 2003, the Nation moved for reconsideration of the February 3 Order Withholding Per Capita. On March 12, the Trial Court entered an order denying this motion. On March 17, the Trial Court entered a corrected Order Withholding Per Capita For Incarceration Fees and Fines, which reduced the amount to be deducted from Haynes’ per capita from $2,250 to $1,650,

On March 19, 2003, the Nation filed a Notice of Appeal from the February 3, March 12 and March 17 orders, and on April 4, 2003, it moved in this Court for a stay of execution, pending appeal, of those orders. This matter was consolidated with three other cases, which raised similar issues as to whether the Trial Court had the authority to order a criminal defendant’s fines and costs to be deducted from his Per Capita allocation. In its April 22, 2003 opinion, this Court found that the appeals filed in the other three cases should be dismissed for lack of timeliness. Fort McDowell Yavapai Nation vs. Bemon Thomas, Emery Smith, Sr., Darrell Isaac & Darold Haynes (Fort McDowell Yavapai Supreme Court, April 22, 2003). In the Thomas, Smith and Isaac cases, the notices of appeal were filed long after the expiration of the five-judicial-day period during which such a notice must be filed pursuant to Section 4^34(A) of the Nation’s Law and Order Code. This Court therefore dismissed the appeals in those cases and denied the motions for stays pending appeals in those cases.

In the Haynes case, however, this Court found that the appeal was filed within the required five-judicial-day period. Moreover, this Court held that the Haynes per capita, order should be stayed pending our decision on the merits of the Nation’s ap[219]*219peal. The Haynes appeal was fully briefed and then argued on June 13, 2003. This opinion addresses the merits of the appeal and holds that the Trial Court erred in issuing the Order Withholding Per Capita.

DISCUSSION

In order to resolve the issue on appeal, this Court must interpret recent Tribal Council actions regarding per capita payments to tribal members who are accused of or convicted of criminal offenses. Prior to these recent changes, qualified tribal members accused or convicted of crimes were entitled to continue receiving their per capita benefits. Moreover, in sentencing a person convicted of an offense, the Trial Court was authorized by Section 8-3(b) of the Law and Order Code to order certain costs to be deducted from these payments. Section 8—3(b) provides that:

If the offender is a member of the Fort McDowell Yavapai Nation and is currently receiving per capita payments from the Fort McDowell Yavapai Nation, the [sentencing] court may order that [certain listed] costs be deducted from the offender’s monthly per capita payments and be paid to the victim or the Nation.

The costs that could be ordered deducted under Section S—3(b) were “restitution to the victim of the offense,” “the cost of [the offender’s] incarceration,” certain “costs directly incurred and reasonably necessary for the investigation of the offense,” and the “cost of services, counseling, treatment and rehabilitation provided or arranged by the Fort McDowell Family and Community Services.” Law and Order Code, Section 8(a).

A. The 2003 Revenue Allocation Plan

In late September, 2002, the Tribal Council acted to change this situation in its Revenue Allocation Plan (“RAP”) for the 2003 fiscal year (the Nation’s fiscal year begins on October 1). Section VII of the RAP provides- comprehensive guidance on the distribution and allocation of per capita payments to tribal members from the Nation’s gaming revenues and specifies that per capita benefits are paid to “advance the personal health, safety and welfare of qualified tribal members.” The RAP further specifies that “to advance the personal health, safety and welfare of qualified tribal members and the Nation, per capita distributions shall be suspended and forfeited,” for adult and minor members alike, “upon the following types of negative behaviors.” RAP, Section VII(C). In relevant part to the facts of this case, the RAP provides that:

1. • Suspension—Per Capita payments shall be suspended until a final court finding of guilt or innocence for [arrest of a tribal member for a list of enumerated offenses, including] any alcohol and/or drag related crime.
2. Forfeiture—Per Capita payments shall be forfeited dating back from the time of arrest until the person’s court sentence has been completely served.

After offering an example, the RAP provides that “fpjer capita payments are forfeited” for “[cjonviction for any alcohol or drug related crime,” as well as the other enumerated offenses.

Finally, Section VII(C) provides that “[p]ayments for child support, tribal loans and any other tribal payments and reimbursements to the Nation shall be paid first, then any forfeited proceeds shall be placed in a separate account to fund government programs dealing with the above offenses.”

Tribal members were informed of this change in a memorandum, dated September 3QV 2002, that was addressed;by-the Council to tribal members. This memo[220]*220randum generally reproduced the relevant language in the RAP, except that, in describing the payments that should be paid out of forfeited proceeds prior to those proceeds being placed in a separate account, the memorandum included payments for “court orders,” and mentioned “housing, etc.” as an example of “other tribal payments.”

11. The January 200:1 Amendment to the RAP

Free access — add to your briefcase to read the full text and ask questions with AI

Cite This Page — Counsel Stack

Bluebook (online)
4 Am. Tribal Law 217, Counsel Stack Legal Research, https://law.counselstack.com/opinion/fort-mcdowell-yavapai-nation-v-haynes-ftmcdowell-2003.