United States v. Seth Henry Big Crow

523 F.2d 955, 1975 U.S. App. LEXIS 12456
CourtCourt of Appeals for the Eighth Circuit
DecidedOctober 7, 1975
Docket75-1164
StatusPublished
Cited by38 cases

This text of 523 F.2d 955 (United States v. Seth Henry Big Crow) is published on Counsel Stack Legal Research, covering Court of Appeals for the Eighth 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. Seth Henry Big Crow, 523 F.2d 955, 1975 U.S. App. LEXIS 12456 (8th Cir. 1975).

Opinion

LAY, Circuit Judge.

The defendant, Seth Henry Big Crow, an Indian, was indicted under the Major Crimes Act, 18 U.S.C. § 1153, for assault with a dangerous weapon (Count I), assault resulting in serious bodily injury (Count II), and burglary (Count III). The alleged offenses occurred on the Rosebud Indian Reservation in the State of South Dakota. After trial by jury, the defendant was convicted as charged on Count II and of lesser included offenses on the two remaining counts. He received sentences of 90 days on Count I and three years on Count III, each to run concurrently with a five-year sentence he received on Count II.

Only the convictions on Counts II and III are challenged on appeal. The defendant argues that his conviction on Count II is invalid in that he received a greater sentence than a non-Indian could have received for the same offense, in violation of the Fifth Amendment Due Process Clause. On Count III he argues that the district court committed plain error in its instructions to the jury. The conviction on Count II is reversed and remanded for dismissal by the district court. The conviction on Count III is affirmed.

I. Count II: Assault Resulting in Serious Bodily Injury Under 18 U.S.C. § 1153.

The Major Crimes Act, 18 U.S.C. § 1153 1 provides that certain offenses by *957 Indians within a reservation must be tried in federal courts. The Act also provides that some of these federal offenses, including assault resulting in serious bodily injury of which defendant was convicted on Count II, are to be defined and punished according to the laws of the state in which the offense was committed. In the instant case, the government selected the following South Dakota statute to define the essential elements and punishment under Count II:

Assault with intent to inflict great bodily injury. — Whoever assaults another with intent to inflict great bodily injury shall be punished upon conviction thereof by imprisonment in the state penitentiary for not less than one year, nor more than five years, or in the county jail not exceeding one year, or by a fine not exceeding five hundred dollars, or by both such fine and imprisonment.

SDCL 22-18-12.

The defendant argues that a non-Indian who committed the same offense would be subject to a maximum sentence of six months, rather than the five years imposed on the defendant under § 1153. Thus, defendant argues that as applied here, § 1153 unlawfully discriminates against Indians in violation of the Fifth Amendment Due Process Clause and contrary to the express language of that statute, fails to “subject [Indians] to the same laws and penalties as all other persons” committing this offense “within the exclusive jurisdiction of the United States.”

A non-Indian cannot be charged under 18 U.S.C. § 1153 so as to incorporate state law, since the Act applies exclusively to Indians. A non-Indian who commits an identical assault on a federal enclave is governed by that portion of 18 U.S.C. § 1152 which extends federal criminal jurisdiction to crimes committed by non-Indians against Indians on reservations. 2 On this basis, the defendant contends that a non-Indian would have to be charged under subsection (d) of 18 U.S.C. § 113, the federal statute proscribing assaults. 3 Thus a non-Indian committing an assault upon an Indian on the reservation is Subject to only six months imprisonment, whereas an Indian committing the identical crime is subject to up to five years imprisonment. The defendant urges that he is denied equal protection of the laws in violation of the Due Process Clause of the Fifth Amendment. Cf. Bolling v. Sharpe, 347 U.S. 497, 74 S.Ct. 693, 98 L.Ed. 884 (1954).

The government argues in response that a non-Indian would in fact *958 be chargeable under the same state statute and subject to the same sentence as the defendant. The government asserts that the Assimilative Crimes Act, 18 U.S.C. § 13, requires this result. The Assimilative Crimes Act provides:

Whoever within or upon any of the places now existing or hereafter reserved or acquired as provided in section 7 of this title, is guilty of any act or omission which, although not made punishable by any enactment of Congress, would be punishable if committed or omitted within the jurisdiction of the State, Territory, Possession, or District in which such place is situated, by the laws thereof in force at the time of such act or omission, shall be guilty of a like offense and subject to a like punishment, (emphasis added).

Under 18 U.S.C. § 13, the government can resort to state law only if no Act of Congress makes a defendant’s conduct punishable. United States v. Sharpnack, 355 U.S. 286, 78 S.Ct. 291, 2 L.Ed.2d 282 (1958); Williams v. United States, 327 U.S. 711, 66 S.Ct. 778, 90 L.Ed. 962 (1946). The government urges that that is the case here, for “assault resulting in serious bodily injury” is actually assault and battery, while 18 U.S.C. § 113 in its view covers only assault, not actual batteries.

We disagree. In our view, 18 U.S.C. § 113(d) makes the offense of assault resulting in serious bodily injury punishable by an Act of Congress within the meaning of the Assimilative Crimes Act so as to bar resort to state law. Section 113(d) punishes “assault by striking, beating, or wounding.” 4

The fact that an assault actually results in serious bodily injury does not preclude use of § 113(d), even though that result is not an essential element of that offense. If the government believes that the maximum punishment under § 113 is inadequate for some aggravated assaults, the remedy lies in Congress, not in substitution at the prosecutor’s discretion of the state law for federal law.

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Bluebook (online)
523 F.2d 955, 1975 U.S. App. LEXIS 12456, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-seth-henry-big-crow-ca8-1975.