United States v. Smith

100 F.4th 1244
Court of Appeals for the Tenth Circuit·Decided May 7, 2024·No. 22-2142·Published·Cited by 3 cases

Opinion

Appellate Case: 22-2142 Document: 010111045349 Date Filed: 05/07/2024 Page: 1 FILED United States Court of Appeals PUBLISH Tenth Circuit

UNITED STATES COURT OF APPEALS May 7, 2024

Christopher M. Wolpert FOR THE TENTH CIRCUIT Clerk of Court _________________________________

UNITED STATES OF AMERICA,

Plaintiff - Appellee,

v. No. 22-2142

DOUGLAS D. SMITH,

Defendant - Appellant.

-------------------------------------

STATE OF NEW MEXICO; PUEBLOS OF SANTA CLARA; ACOMA; COCHITI; ISLETA; LAGUNA AND ZIA; AND THE ZUNI TRIBE; AND THE ALL PUBELO COUNCIL OF GOVERNORS,

Amicus Curiae. _________________________________

Appeal from the United States District Court for the District of New Mexico (D.C. No. 1:18-CR-03495-JCH-1) _________________________________

Aric Grant Elsenheimer, Assistant Federal Public Defender, Albuquerque, New Mexico, for Defendant-Appellant Douglas Smith.

Tiffany L. Walters, Assistant United States Attorney, Albuquerque, New Mexico (Alexander M. M. Uballez, United States Attorney, with her on the brief), for Plaintiff- Appellee United States of America.

Raúl Torrez, Attorney General, Aletheia V.P. Allen, Solicitor General, Albuquerque, New Mexico, and Ellen Venegas, Assistant Attorney General, Santa Fe, New Mexico, filed an amici brief for the State of New Mexico, on behalf of Plaintiff-Appellee. Appellate Case: 22-2142 Document: 010111045349 Date Filed: 05/07/2024 Page: 2

Richard W. Hughes and Donna M. Connolly, Rothsten Donatelli LLP, Santa Fe New Mexico, for Pueblos of Santa Clara, Acoma, and Laguna, and All Pueblo Council of Governors; C. Bryant Rogers, VanAmberg, Rogers, Yepa, Abeita Gomez & Wilkinson LLP, Santa Fe, New Mexico, for Pueblo of Cochiti; Lindsay Cutler, Pueblo of Isleta, Isleta, New Mexico, for Pueblo of Isleta; and David C. Mielke, Sonosky, Chambers, Sachse, Mielke & Brownell, LLP, Albuquerque, New Mexico, for Pulebo of Zia and Zuni Tribe, filed an amicus curiae brief on behalf of Plaintiff-Appellee. _________________________________

Before HARTZ, EBEL, and CARSON, Circuit Judges. _________________________________

CARSON, Circuit Judge. _________________________________

Indian Pueblo law is a jigsaw puzzle of statute, precedent, and history with

pieces scattered across centuries. Though legitimate queries remain, this Court’s

precedent instructs us to recognize federal criminal jurisdiction over land owned by

non-Indians within the exterior boundaries of a Pueblo. A federal jury convicted

Douglas Smith—a non-Indian—of involuntary manslaughter for an act he committed

on property located within the exterior boundaries of the Pueblo of Santa Clara.

Defendant challenges the district court’s jurisdiction and his sentence. Exercising

jurisdiction under 28 U.S.C. § 1291, we affirm.

2 Appellate Case: 22-2142 Document: 010111045349 Date Filed: 05/07/2024 Page: 3

I.

Defendant owned and lived at 826 N. Riverside Drive, Española, New Mexico.

Although the property is located within the exterior boundaries of the Pueblo of

Santa Clara, Defendant is not an Indian and owned fee simple title to the property.

In the early morning, Defendant saw Maria Gallegos trying to break into a

trailer on his property. Defendant shot and killed Gallegos. The grand jury indicted

Defendant with second-degree murder in violation of 18 U.S.C. § 1111, but a jury

convicted Defendant of a lesser included offense—involuntary manslaughter in

violation of 18 U.S.C. § 1112—and the district court sentenced Defendant to twenty-

seven months’ imprisonment.

Before trial, Defendant moved to dismiss the case for lack of federal

jurisdiction, arguing (1) that the federal district court lacked criminal jurisdiction

over crimes committed on his property, and (2) that Congress acted outside its

constitutional authority when it passed the Indian Pueblo Land Act Amendments of

2005, Pub. L. No. 109–133, 119 Stat. 2573 (“2005 Amendment”). The district court

denied his motion. Defendant appeals the district court’s denial of his motion to

dismiss and his sentence.

II.

We must decide whether federal criminal jurisdiction extends to land owned

by a non-Indian within the exterior boundaries of a Pueblo. In addressing this

question, we review a defendant’s challenge to criminal jurisdiction de novo. United

3 Appellate Case: 22-2142 Document: 010111045349 Date Filed: 05/07/2024 Page: 4

States v. Brown, 164 F.3d 518, 521 (10th Cir. 1998) (citing United States v.

Blackwell, 81 F.3d 945, 947 (10th Cir. 1996)).

A.

Congress has established federal criminal jurisdiction over crimes committed

within “Indian country.” 18 U.S.C. § 1152. As defined by 18 U.S.C. § 1151,

“Indian country” refers to:

(a) all land within the limits of any Indian reservation under the jurisdiction of the United States Government, notwithstanding the issuance of any patent, and, including rights-of-way running through the reservation, (b) all dependent Indian communities within the borders of the United States whether within the original or subsequently acquired territory thereof, and whether within or without the limits of a state, and (c) all Indian allotments, the Indian titles to which have not been extinguished, including rights-of-way running through the same.

To determine the reach of federal criminal jurisdiction, we must therefore decide

whether the property on which Defendant shot Maria Gallegos is part of either an

Indian reservation, a dependent Indian community, or an Indian allotment.

The Supreme Court defined the Pueblos as “dependent Indian communities” in

United States v. Sandoval, 231 U.S. 28, 46–47 (1913). Thus, Pueblo lands are Indian

country within the meaning of 18 U.S.C. § 1151(b) and subject to federal criminal

jurisdiction under 18 U.S.C. § 1152. Accord United States v. Antonio, 936 F.3d

1117, 1121 (10th Cir. 2019). But 18 U.S.C. § 1151(b) “did not account for tracts of

4 Appellate Case: 22-2142 Document: 010111045349 Date Filed: 05/07/2024 Page: 5

land within the dependent Indian communities that were owned by non-Indians.”1

Antonio, 936 F.3d at 1121. Defendant therefore argues that his property is beyond

federal criminal jurisdiction because a non-Indian owns it, though it is within the

exterior boundaries of a Pueblo. We disagree.

Congress enacted § 12 of the Trade and Intercourse Act of 1834, prohibiting

“purchase, grant, lease, or other conveyance of lands, or of any title or claim thereto,

from any Indian nation or tribe of Indians.” 25 U.S.C.

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