State v. McCormack

793 P.2d 682, 117 Idaho 1009, 1990 Ida. LEXIS 24
CourtIdaho Supreme Court
DecidedFebruary 27, 1990
Docket17742, 17898
StatusPublished
Cited by27 cases

This text of 793 P.2d 682 (State v. McCormack) is published on Counsel Stack Legal Research, covering Idaho Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
State v. McCormack, 793 P.2d 682, 117 Idaho 1009, 1990 Ida. LEXIS 24 (Idaho 1990).

Opinions

BOYLE, Justice.

James McCormack and Casey Cree, both enrolled members of the Néz Perce Tribe, challenge the jurisdiction of the State of Idaho to require them to submit to breath tests under Idaho’s implied consent statute, I.C. § 18-8002. The cases are consolidated on appeal because similar facts and identical legal issues are presented to the Court.

McCormack was driving a motor vehicle on U.S. Highway 95 within the Nez Perce [1010]*1010Indian Reservation in Lewis County when he was stopped by a deputy sheriff, arrested and advised that he must submit to an evidentiary breath alcohol test or, upon refusal to take the test, have his driving privileges suspended for one hundred eighty days. McCormack voluntarily submitted to the evidentiary test. He was charged with driving under the influence of intoxicants, in violation of I.C. § 18-8004. The charge was subsequently reduced to a misdemeanor in violation of I.C. § 18-8005(2) to which McCormack entered a conditional plea of guilty under I.C.R. 11(a)(2), and appeals the magistrate’s denial of his motion to suppress the results of the evidentiary test.

Casey Cree was driving a motor vehicle on Highway 12 within the Nez Perce Indian Reservation in Nez Perce County when he was stopped by a member of the Idaho State Police, arrested and transported to the Lewiston Police Department where he was advised that he must submit to an evidentiary breath test or have his driving privileges suspended for one hundred eighty days. Cree also voluntarily submitted to the evidentiary test. Cree thereafter entered a conditional plea of guilty, and now appeals from the judgment of conviction and the magistrate court’s denial of his motion to suppress the results of his test.

The only issues on appeal before this Court are those specific issues which were reserved in the written conditional plea agreements of each defendant. I.C.R. 11(a)(2) clearly requires that any issue desired to be reserved for appeal must be specified in writing.1 McCormack specifically reserved a challenge to the use of the breath test as being beyond the jurisdiction granted to the state of Idaho,2 and Cree specifically reserved the right to appeal the district court’s decision denying his motion to suppress the breath test because he was an Indian arrested within the boundaries of a reservation.3 In addition, Cree reserved the issue of the increased suspension period in I.C. § 18-8002. We conclude that both defendants properly reserved their rights to appeal the jurisdictional issues.

In both of these consolidated cases, defendants challenge the jurisdiction of the State of Idaho to require them to submit to a test of their breath under the implied consent statute, I.C. § 18-8002, on the grounds that as Indians, arrested within the boundaries of the Nez Perce Indian Reservation, 1) the state has not obtained the consent of the Nez Perce Tribe for any new assumption of criminal jurisdiction; 2) the penalty has been doubled from ninety to one hundred eighty days without the necessary consent of the Nez Perce Tribe; and/or 8) the statute is civil/regulatory in nature and the state has never assumed or been granted that jurisdiction.

Defendants first contend that I.C. § 18-80024 is an increased penalty crime [1011]*1011and, as such, is an assumption of a new criminal jurisdiction requiring tribal consent. Defendants assert that the State has not obtained consent from the Nez Perce Tribe for assumption of this new criminal jurisdiction, and consequently I.C. § 18-8002, requiring an evidentiary test, seizure of license and an increased suspension term upon refusal to take the breath test, is not enforceable against tribal members when arrested or cited in Indian Country. Indian Country is defined by Congress as that land within the limits of an Indian reservation. 18 U.S.C. § 1151.

Public Law 280, passed by Congress on August 15, 1953, automatically transferred to five states, and offered all other states, certain limited jurisdiction over Indians within Indian Country. Act of Aug. 15, 1953, ch. 505, § 7, 67 Stat. 590, as amended 25 U.S.C. §§ 1321-1326 (1970), is commonly referred to as Public Law 280. The United States Supreme Court determined that Congress’ motivation for enacting Public Law 280 “was centrally to curb lawlessness on the reservations and secondarily to cure the lack of adequate Indian forums for resolving private disputes.” Sheppard v. Sheppard, 104 Idaho 1, 13, 655 P.2d 895, 907 (1982), citing Bryan v. Itasca County, 426 U.S. 373, 96 S.Ct. 2102, 48 L.Ed.2d 710 (1976).

In several prior decisions of this Court we have carefully analyzed the legislative history and policy of Public Law 280 and the various amendments to that statute, as well as the Idaho legislation that has followed since its enactment. Sheppard v. Sheppard, 104 Idaho 1, 655 P.2d 895 (1982); State v. Major, 111 Idaho 410, 725 P.2d 115 (1986); State v. Michael, 111 Idaho 930, 729 P.2d 405 (1986). It is not necessary for purposes of this appeal to restate that legislative process and history in detail, nor is it necessary to restate the entire body of law that has developed in this state as a result of Congress’ enactment of Public Law 280 other than to refer to the guiding canons of construction and the basic legal principles involved when dealing with state jurisdiction over Indians. Indian tribal members are generally under the exclusive jurisdiction of the United States Government; however, states may be given specific authority by Congress over certain Indian affairs that affect the various states. United States v. McGowan, 302 U.S. 535, 58 S.Ct. 286, 82 L.Ed. 410 (1938); State v. Michael, 111 Idaho 930, 729 P.2d 405 (1986); Boyer v. Shoshone-Bannock Indian Tribes, 92 Idaho 257, 441 P.2d 167 (1968). When addressing issues of state jurisdiction in Indian Country, we are guided by the canon of construction that state and federal legislation passed for the benefit of Indians is to be construed in the Indians’ favor. State v. Major, 111 Idaho 410, 725 P.2d 115 (1986); Sheppard [1012]*1012v. Sheppard, 104 Idaho 1, 655 P.2d 895 (1982). Likewise, statutes and legislation involving Indian rights are to be construed liberally in favor of the Indians, with any ambiguous provisions interpreted to their benefit in order to respect and preserve the vestigial Indian sovereignty. State v. Major, 111 Idaho at 416, 725 P.2d at 121.

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

Related

State v. Robert Wesley Warden
Idaho Court of Appeals, 2016
State v. Manzanares
272 P.3d 382 (Idaho Supreme Court, 2012)
State v. Yallup
248 P.3d 1095 (Court of Appeals of Washington, 2011)
State v. Beasley
199 P.3d 771 (Idaho Court of Appeals, 2008)
State v. Harrison
2008 NMCA 107 (New Mexico Court of Appeals, 2008)
State v. DeWitt
184 P.3d 215 (Idaho Court of Appeals, 2008)
State v. Ambro
123 P.3d 710 (Idaho Court of Appeals, 2005)
State v. Barros
957 P.2d 1095 (Idaho Supreme Court, 1998)
State v. Warden
906 P.2d 133 (Idaho Supreme Court, 1995)
State v. Smith
862 P.2d 1093 (Idaho Court of Appeals, 1993)
Nez Perce Tribe v. Cenarrusa
867 P.2d 911 (Idaho Supreme Court, 1993)
State v. Snyder
807 P.2d 55 (Idaho Supreme Court, 1991)
State v. Thompson
803 P.2d 973 (Idaho Supreme Court, 1990)
State v. Taylor
797 P.2d 158 (Idaho Court of Appeals, 1990)
State v. McCormack
793 P.2d 682 (Idaho Supreme Court, 1990)

Cite This Page — Counsel Stack

Bluebook (online)
793 P.2d 682, 117 Idaho 1009, 1990 Ida. LEXIS 24, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-mccormack-idaho-1990.