United States v. Peshlakai

CourtCourt of Appeals for the Tenth Circuit
DecidedAugust 1, 2025
Docket24-2156
StatusUnpublished

This text of United States v. Peshlakai (United States v. Peshlakai) is published on Counsel Stack Legal Research, covering Court of Appeals for the Tenth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
United States v. Peshlakai, (10th Cir. 2025).

Opinion

Appellate Case: 24-2156 Document: 32-1 Date Filed: 08/01/2025 Page: 1 FILED United States Court of Appeals Tenth Circuit UNITED STATES COURT OF APPEALS August 1, 2025 FOR THE TENTH CIRCUIT _________________________________ Christopher M. Wolpert Clerk of Court UNITED STATES OF AMERICA,

Plaintiff - Appellee,

v. No. 24-2156 (D.C. No. 1:21-CR-01501-JCH-1) RUMALDO PESHLAKAI, (D. N.M.)

Defendant - Appellant. _________________________________

ORDER AND JUDGMENT* _________________________________

Before HOLMES, Chief Judge, MORITZ, and ROSSMAN, Circuit Judges. _________________________________

Rumaldo Peshlakai, a member of the Navajo Nation, pled guilty to

violating 18 U.S.C. § 922(g)(1)—the federal felon-in-possession statute. Before

entering into a plea agreement, Mr. Peshlakai had filed a motion to suppress.

He argued his federal arrest on the charged offense was unlawful because the

FBI failed to follow the procedures in the Navajo Nation’s federal detainer

statute, Navajo Nation Code Ann. tit. 17, §§ 1962–66 (2017) (the Detainer

Statute). The district court rejected that argument and denied the motion,

* This order and judgment is not binding precedent, except under the

doctrines of law of the case, res judicata, and collateral estoppel. It may be cited, however, for its persuasive value consistent with Fed. R. App. P. 32.1 and 10th Cir. R. 32.1. Appellate Case: 24-2156 Document: 32-1 Date Filed: 08/01/2025 Page: 2

concluding the Detainer Statute did not apply in Mr. Peshlakai’s

circumstances. Mr. Peshlakai now appeals the district court’s order denying

his motion to suppress. But he never explains in his opening brief why

suppression is available even assuming the Detainer Statute was violated, and

he never responds to the government’s contrary argument that suppression is

not an appropriate remedy. Exercising jurisdiction under 28 U.S.C. § 1291, we

affirm.

I

A1

The events relevant to this appeal occurred within the Navajo

Reservation. Mr. Peshlakai and his wife, C.P., are members of the Navajo

Nation.

On September 23, 2021, C.P. called dispatch for the Navajo Police

Department (NPD). She reported Mr. Peshlakai assaulted her, took their four

children, and fled in a truck with a firearm. The NPD contacted the FBI to

assist with the investigation. NPD officers then located Mr. Peshlakai’s truck

1 We take these background facts from the appellate record, including

the district court’s order on Mr. Peshlakai’s motion to suppress. The parties do not dispute these facts unless otherwise noted. See United States v. Hudson, 210 F.3d 1184, 1190 (10th Cir. 2000) (“In reviewing a district court’s ruling on a motion to suppress, this court accepts the district court’s factual findings unless clearly erroneous . . . .”). 2 Appellate Case: 24-2156 Document: 32-1 Date Filed: 08/01/2025 Page: 3

in a secluded area, and FBI agents soon joined them. The officers did not find

Mr. Peshlakai or his children in the truck.

The officers then set up a “command post” at the NPD’s Window Rock

station. RI.160. That evening, Mr. Peshlakai called NPD dispatch and spoke to

FBI agents. He said the children were safe with his mother, which the NPD

and FBI confirmed. He also agreed to turn himself in the next morning.

On the morning of September 24, Mr. Peshlakai reported to the Window

Rock station. Three NPD officers met him outside. One of the NPD officers told

Mr. Peshlakai he was under arrest and handcuffed him “in a rough manner.”

RI.161; RIII.62; see RIII.63, 65 (Mr. Peshlakai describing the arrest). The

officers briefly placed Mr. Peshlakai in an NPD vehicle and then brought him

to the NPD booking area, where he took a COVID test. But Mr. Peshlakai was

not booked. Instead, the officers brought him to a different part of the station

and held him there for thirty to forty-five minutes.

Then FBI agent Curtis Imming arrived. Agent Imming uncuffed

Mr. Peshlakai, read him his Miranda rights, and questioned him.

Mr. Peshlakai shared information about his domestic issues and firearm

possession. Because Mr. Peshlakai had a previous conviction for felony assault,

Agent Imming arrested him for possessing a firearm after a felony conviction,

in violation of 18 U.S.C. § 922(g)(1).

3 Appellate Case: 24-2156 Document: 32-1 Date Filed: 08/01/2025 Page: 4

B

On October 14, 2021, a federal grand jury in the District of New Mexico

charged Mr. Peshlakai with violating § 922(g)(1).

On April 29, 2023, Mr. Peshlakai moved to suppress evidence “obtained

. . . when FBI Agents . . . conduct[ed] their investigation and arrest.” RI.48.

The crux of Mr. Peshlakai’s argument was that his federal arrest violated the

Detainer Statute and, therefore, violated the Fourth Amendment. In support,

Mr. Peshlakai first contended “the Navajo Nation has a sovereign right not to

release tribal defendants to other sovereigns except in accordance with

appropriate procedures.” RI.51 (citing, inter alia, Treaty Between the United

States of America and the Navajo Tribe of Indians, 15 Stat. 667 (1868)2). And

these “appropriate procedures,” Mr. Peshlakai argued, are “set forth in the

2 Mr. Peshlakai was likely referencing this provision of the 1868 Treaty:

If bad men among the Indians shall commit a wrong or depredation upon the person or property of any one, white, black, or Indian, subject to the authority of the United States and at peace therewith, the Navajo tribe agree that they will, on proof made to their agent, and on notice by him, deliver up the wrongdoer to the United States, to be tried and punished according to its laws; and in case they wilfully refuse so to do, the person injured shall be reimbursed for his loss from the annuities or other moneys due or to become due to them under this treaty, or any others that may be made with the United States.

Treaty Between the United States of America and the Navajo Tribe of Indians, 15 Stat. 667, 667 (1868); see United States v. Fox, 573 F.3d 1050, 1054–55 (10th Cir. 2009) (discussing this provision). 4 Appellate Case: 24-2156 Document: 32-1 Date Filed: 08/01/2025 Page: 5

[Detainer Statute], 17 N.N.C. §§ 1962-1966.” RI.52. But according to

Mr. Peshlakai, the FBI “arrested [him] without following the [Detainer

Statute] protocols.” RI.53. For example, he argued, the FBI “failed to submit a

federal detainer request,” which the Detainer Statute requires. RI.53; see

Navajo Nation Code Ann. tit. 17, § 1963.

To show the FBI’s failure to follow the Detainer Statute constituted a

Fourth Amendment violation, Mr. Peshlakai invoked our decision in Ross v.

Neff, 905 F.2d 1349 (10th Cir. 1990). In Ross, an Oklahoma police officer

arrested an Indian suspect in Indian Country. See id. at 1351–52; see also

18 U.S.C. § 1151 (defining “Indian Country”).

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

Related

Walder v. United States
347 U.S. 62 (Supreme Court, 1954)
United States v. Smith
606 F.3d 1270 (Tenth Circuit, 2010)
United States v. Hudson
210 F.3d 1184 (Tenth Circuit, 2000)
United States v. Minjares-Alvarez
264 F.3d 980 (Tenth Circuit, 2001)
Elkins v. Comfort
392 F.3d 1159 (Tenth Circuit, 2004)
United States v. Fox
573 F.3d 1050 (Tenth Circuit, 2009)
Ross v. Neff
905 F.2d 1349 (Tenth Circuit, 1990)
Perry v. Woodward
199 F.3d 1126 (Tenth Circuit, 1999)
United States v. Jones
701 F.3d 1300 (Tenth Circuit, 2012)
United States v. Adams
740 F.3d 40 (First Circuit, 2014)
United States v. Watson
766 F.3d 1219 (Tenth Circuit, 2014)
Eizember v. Trammell
803 F.3d 1129 (Tenth Circuit, 2015)
Eaton v. Pacheco
931 F.3d 1009 (Tenth Circuit, 2019)
Hardy v. City Optical Inc.
39 F.3d 765 (Seventh Circuit, 1994)
Burke v. Regalado
935 F.3d 960 (Tenth Circuit, 2019)
Hasan v. Aig Prop. Cas. Co.
935 F.3d 1092 (Tenth Circuit, 2019)

Cite This Page — Counsel Stack

Bluebook (online)
United States v. Peshlakai, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-peshlakai-ca10-2025.