Intersecting Laws: The Tribal Law And Order Act And The .
Intersecting Laws: theTribal Law and OrderAct and the IndianCivil Rights ActCONTRIBUTING AUTHORS AND EDITORSBj Jones , Director, Tribal Judicial Institute, University Of North Dakota School Of LawMichelle Rivard Parks, Associate Director, Tribal Judicial Institute, University Of North Dakota School Of LawCONTRIBUTING AUTHORSMichael Merner, Law Clerk, Tribal Judicial Institute, University Of North Dakota School Of LawMitch Enright, Law Clerk, Tribal Judicial Institute, University Of North Dakota School Of LawEkta Patel, Law Clerk, Tribal Judicial Institute, University Of North Dakota School Of LawOCTOBER, 2016This publication is not designed to offer legal advice to any Tribe or individual and should not be construed that way.Tribes and others should always confer with independent legal counsel about legal issues raised in this publication.
Table of ContentsI. INTRODUCTION . 3A. The Indian Civil Rights Act . 3B. The Tribal Law and Order Act of 2010 . 5II. Rights of Defendants and Inmates . 8A. Cruel and Unusual Punishment. 9B. The Tribal Law and Order Act’s Application of Constitutional Standards . 10III.Tribal Considerations When Implementing Enhanced Sentencing . 14A. Prison or Detention Facility Considerations . 14B. Uncounseled Convictions and the Extent of the Right to Legal Counsel . 16C.The Right to Indigent Defense . 171. Federal Standards . 182. State Standards . 203. Tribal Standards . 21D. Post-Conviction Right to Counsel (Habeas Corpus) . 22E. Determining Indigent Status . 231. Federal Poverty Guidelines . 232. State Guidelines. 23F.Posting Bond . 24G.Recovering Indigent Defendant Counsel Costs . 241. Recoupment . 252. Application Fees . 25H. Federal Habeas Review. 26IV. CONCLUSION . 282
I.INTRODUCTIONA.The Indian Civil Rights Act1Civil rights laws, in general, set limitations on governmental actions as a means to protectindividuals from actual or potential abuse by a government.2 The U.S. Constitution and, morespecifically, the Bill of Rights provide such protections against abuses by federal, state, and localgovernments. However, prior to 1968, and due to the U.S. Supreme Court decision in Talton v.Mayes that the federal constitution did not apply to tribal governmental action, there was nofederal legislation protecting individual tribal members against abuses by tribal governments.3 In1968, with the enactment of the Indian Civil Rights Act (hereinafter “ICRA”), Congress set forthspecific civil rights that would serve to protect tribal members, other persons, and Indiancommunities from civil rights abuses by tribal governments.4 ICRA, as subsequently amended,mandated that no Indian tribe exercising powers of self-government shall:(1) [M]ake or enforce any law prohibiting the free exercise of religion, orabridging the freedom of speech, or of the press, or the right of the peoplepeaceably to assemble and to petition for a redress of grievances; (2) violate theright of the people to be secure in their persons, houses, papers, and effectsagainst unreasonable search and seizures, nor issue warrants, but upon probablecause, supported by oath or affirmation, and particularly describing the place to besearched and the person or thing to be seized; (3) subject any person for the sameoffense to be twice put in jeopardy; (4) compel any person in any criminal case tobe a witness against himself; (5) take any private property for a public use withoutjust compensation; (6) deny to any person in a criminal proceeding the right to aspeedy and public trial, to be informed of the nature and cause of the accusation,to be confronted with the witnesses against him, to have compulsory process forobtaining witnesses in his favor, and at his own expense to have the assistance ofcounsel for his defense; (7) require excessive bail, impose excessive fines, inflictcruel and unusual punishments, and in no event impose for conviction of any oneoffense any penalty or punishment greater than imprisonment for a term of one118 U.S.C. § 1302.Stephan L. Pevar, The Rights of Indians and Indian Tribes (4th Edition 2014). Pg. 221.3Id.4Ed Hermes, Law & Order Tribal Edition: How The Tribal Law and Order Act Has Failed To Increase Tribal Court Sentencing Authority,Arizona State Law Journal (Summer 2013). Pg. 685.23
year and a fine of 5,000, or both; (8) deny to any person within its jurisdictionthe equal protection of its laws or deprive any person of liberty or propertywithout due process of law; (9) pass any bill of attainder or ex post facto law; or(10) deny to any person accused of an offense punishable by imprisonment theright, upon request, to a trial by jury of not less than six persons.5ICRA incorporated many of the same provisions set forth in the Bill of Rights and madethem applicable to tribal governments and judicial systems.6 In Talton v. Mayes (1896), the U.S.Supreme Court held that because Indian tribes predated the U.S. Constitution and did not derivetheir authority from it, they were not subject to the constitutional limitations of the FifthAmendment.7 Furthermore, because tribes are not states, the constitutional restrictions on stateactions under the 14th Amendment were not applicable.8 In 1978, the Supreme Court, analyzinga congressional hearing that preceded the passing of ICRA, stated, “[w]e note at the outset that acentral purpose of ICRA and in particular of Title I was to secur[e] for the American Indian thebroad constitutional rights afforded to other Americans, and thereby to protect individual Indiansfrom arbitrary and unjust actions of tribal governments.”9Although ICRA guaranteed substantive personal rights to defendants under tribaljurisdiction, some of the constitutional protections not incorporated in ICRA included therequirement of the separation of church and state, the right to a jury trial in civil cases, and therequirement to provide indigent defendants with appointed counsel.10 ICRA also placed restraintson tribal courts’ imposition of punishment, originally limiting tribal court sentences to sixmonths. However, in 1986, Congress expanded Indian tribes’ sentencing authority under ICRAto one year and a 5,000 fine.11 Under these amendments, it was assumed that a tribe couldimpose a sentence of longer than one year when the suspect was also charged, and convicted, ofdiscrete offenses arising out of the same criminal enterprise. For example, an individual whocommitted both a kidnapping and an aggravated assault of another person could be sentenced tothe maximum of one year on each charge. However, the federal courts have been very restrictiveof this right of Indian tribes to stack maximum sentences under ICRA with at least one525 U.S.C. § 1302.The only exceptions were the Second Amendment right to bear arms, the right to a civil jury trial, the right to indictment in criminalproceedings, and the prohibition against the establishment of a religion.7Robert Probasco, Indian Tribes Civil Rights, and Federal Courts, Texas Wesleyan Law Review (Spring 2001). Pg. 126.8Id.9Santa Clara Pueblo v. Martinez, 436 U.S. 49, 61 (1978); quoting, S.Rep. No. 841, 90th Cong., 1st Sess., 5–6 (1967).10When ICRA was originally enacted in 1968, the U.S. Supreme Court had not yet held that the Fifth Amendment right to counsel included theright to court-appointed counsel for indigent defendants in misdemeanor cases, but rather such right would only be required in felonies. Gideon v.Wainwright, 372 U.S. 335 (1963). It was not until 1972 that the Court decided this right to counsel would also extend to misdemeanors. SeeArgersigner v. Hamlin, 407 U.S. 25, 37, 32 L. Ed. 2d 530, 92 S. Ct. 2006 (1972)("No person may be imprisoned for any offense, whetherclassified as petty, misdemeanor, or felony, unless he was represented by counsel at his trial.").11Hermes, supra, pg. 685; see also 25 U.S.C. § 1302(7).64
concluding that a tribe was foreclosed from punishing separate crimes that were committed aspart of one transaction.12Despite the 1986 amendments to ICRA and the efforts of federal and tribal courts,statistics continued to show that crime in Indian Country was well above the national average.Contributing to the high crime rates were the sentencing restrictions imposed by ICRA and thehigh declination rates by federal prosecutors.13 These factors placed tribal governments in adifficult position in trying to protect their communities.14 In light of these issues, Congresspassed the Tribal Law and Order Act of 2010, a law aimed at decreasing criminal activity inIndian Country.15B.The Tribal Law and Order Act of 2010The Tribal Law and Order Act of 2010 (hereinafter “TLOA”) was signed into law on July29, 2010.16 The purpose of TLOA was to clarify governmental responsibilities regarding crimesin Indian Country; increase and improve collaboration among jurisdictions; support tribal selfgovernance and jurisdiction; reduce the prevalence of violent crime in Indian Country; combatcrimes such as domestic violence, sexual assault, and drug trafficking; reduce the rates ofsubstance abuse in Indian Country; and support the collection and sharing of crime data amongjurisdictions.In addition to the foregoing, TLOA amended ICRA by providing the option for tribes toexpand their sentencing authority within tribal courts.17 By enacting TLOA, Congress recognizedthat the sentencing provisions imposed by ICRA were having a negative impact on tribes’abilities to protect their territory because tribal judicial systems could not impose sentences thatcorresponded to the severity of the crimes being committed. Under pre-existing law, tribes wererestricted to sentences of up to one year in prison and a fine of up to 5,000; however, with theamendments to ICRA, tribes now have an option to enhance sentences in criminal cases byimposing sentences not to exceed three years in prison or fines of 15,000 or both for qualifyingcrimes so long as the tribe has met the specific requirements set forth in TLOA and ICRA asamended. Sentences may include a combination of incarceration and community correctionssuch as probation and halfway houses. Under no circumstance can the term of the sentence12See Spears v. Red Lake Band, 363 F. Supp 2d 1176 (D. Minn. 2005).Id, for example, from 2005-2010, federal prosecutors declined to prosecute roughly 50% of the violent crimes alleged to have occurred ontribal lands and roughly 75% of the sex crimes alleged to have been committed against women and children on Indian reservations.14Id. at 666; see also Jails in Indian Country, U.S. Department of Justice. Accessed at: http://www.bjs.gov/index.cfm?ty pbdetail&iid 5070.15U.S. Department of Justice, Tribal Law and Order Act. Accessed at: http://www.justice.gov/tribal/tloa.html .16Public Law 111–211, 124 Stat. 2258.17Public Law 90–284, 82 Stat. 73 (as amended).135
exceed nine years. Tribes are under no obligation nor mandate to implement enhancedsentencing authority.For those tribes opting to enhance sentencing authority within their tribal courts, section234 (a) (b) and (c) of TLOA mandates that specific requirements be satisfied by the tribe,namely: Defendant is provided effective assistance of counsel at least equal to that under the U.S.Constitution, and at the expense of the tribes for indigent defendants. The tribe must belicensed by any jurisdiction that applies appropriate licensing standards, ensurecompetency, and have rules of professional responsibility. Defendant is not subject to excessive bail, excessive fines, or cruel and unusualpunishment. Presiding judge has sufficient legal training for a criminal proceeding and is licensed inany jurisdiction. All laws, rules of evidence, rules of procedure, etc. are publicly available. Tribe must maintain a record of criminal proceedings (usually audio recording).18In order for offenses to be subject to greater than one year imprisonment or a fine greaterthan 5,000, the person accused of the criminal offense must be someone who: Has been previously convicted of the same or comparable offense by any jurisdiction inthe United States, or Is being prosecuted for an offense comparable to an offense that would be punishable bymore than one year of imprisonment if prosecuted by the United States or any of thestates.19Finally, should a tribe impose a sentence for a qualifying offense that is greater than oneyear of imprisonment or a fine greater than 5,000, certain detention criteria must be met,namely: The facility must be approved by the Bureau of Indian Affairs (BIA) for longtermincarceration, in accordance with guidelines developed by BIA (in consultation withIndian tribes). The facility is the nearest appropriate federal facility, at the expense of the U.S. Bureau ofPrisons (BOP) tribal prisoner pilot program described in section 304(c)[1] of TLOA.1819See TLOA Public Law 11–211, Sec. 234 (a)(1)(2); 234 (c); see also 25 U.S.C. §1302 (c).See TLOA Public Law 111–211, Sec. 234 (a) (3); 25 U.S.C. §1302 (b).6
The facility is a state or local government-approved detention or correctional centerpursuant to an agreement between the Indian tribe and the state or local government, oro The facility is an alternative rehabilitation center of an Indian tribe, oro The defendant may be required to serve another alternative form of punishment,as determined by the tribal court judge pursuant to tribal law.2020See TLOA Public Law 111–211, Sec. 234; 25 U.S.C. §1302 (d).7
II.RIGHTS OF DEFENDANTS AND INMATESICRA extends protections similar to the Eighth Amendment to Indian tribes. This meansthat any tribal member incarcerated in a tribally operated prison or detention center cannot besubjected to “cruel and unusual punishments,” “excessive bail,” or “excessive fines.”21 There is asignificant body of case law regarding cruel and unusual punishment in the context ofincarceration in state and federal facilities, including a number of U.S. Supreme Court decisions.However, it is not clear that these decisions would apply to tribal incarcerations because there islittle or no interpretation of the cruel and unusual punishment clause in ICRA.The Supreme Court decision of Santa Clara Pueblo v. Martinez has stymied federal courtintervention into ICRA violations that do not involve custodial claims, such as jail conditions orother challenges to methods of incarceration rather than the incarceration itself. In the SantaClara Pueblo v. Martinez case, Jennifer Martinez, an enrolled female member of the Santa ClaraPueblo, sued the Pueblo to enjoin the enforcement of a tribal ordinance.22 The ordinance inquestion denied tribal membership to the children of women who married outside of the Pueblo.23Martinez had in fact married outside of the Pueblo and her daughter was thus deniedmembership.24 She claimed that the ordinance violated ICRA’s guarantee of equal protectionbecause she was being discriminated against on the basis of her gender.25In Santa Clara Pueblo v. Martinez, the Supreme Court stated that the protectionsafforded by ICRA are “similar, but not identical, to those contained in the Bill of Rights and theFourteenth Amendment.”26 The Court held that since the only remedy in federal court forviolations of ICRA was the habeas corpus remedy under section 1303, it could not reach themerits of Martinez’s equal protection argument. The Supreme Court strongly implied that thetribal courts would have the right to provide remedies for non-custodial claims in tribal court,although its decision in that case that Indian tribes are typically immune from such suits beliesany clear intent that tribal courts could hear such lawsuits.Similarly, federal courts have not had jurisdiction since Santa Clara Pueblo to addressconditions lawsuits involving tribal prisoners, resulting in this being a very unclear area of thelaw. If the federal court decisions interpreting the Eighth Amendment apply to Indian tribes,tribes would have to ensure adequate ventilation, nutrition, space, access to medical care, access2125 U.S.C. 1302(7).Id. at 51.23Id. at 52.24Id.25Id. at 51.26Id. at 57.228
to legal services, access to exercise, protection from violence from other inmates, and a panoplyof other rights that inmates in federal and state facilities enjoy.Despite the holding in Santa Clara Pueblo, other courts have held that constitutionalstandards do apply for certain violations of ICRA. For example, in United States v. Lester,27 thecourt held that constitutional standards can apply to alleged violations of ICRA’s search andseizure provision (the equivalent of the Fourth Amendment).28 29 Similarly, in Ramos v. PyramidTribal Court, Bureau of Indian Affairs,30 the court declared that, in considering alleged violationsof ICRA’s cruel and unusual punishment provision, judges can refer to constitutional standardsas guidance, but this cannot be the exclusive consideration.31 Clearly, if tribes are incarceratingpersons for up to nine years of detention, certain Eighth Amendment standards would have toapply. To what degree such standards might be deemed applicable remains an unsettled matter.A.Cruel and Unusual PunishmentCourts have found that a number of punitive conditions can be considered “cruel andunusual punishment” and thus constitute a violation of the Eighth Amendment. These conditionsinclude:1) Overcrowding32 – In Rhodes v. Chapman,33 the Supreme Court held that an Ohiomaximum-security prison operating at 38% above its designed capacity did not inflictcruel and unusual punishment upon the inmates lodged therein solely on the basis ofits overcrowding.34 However, other courts have held that severe overcrowding canviolate the Eighth Amendment. For example, in Battle v. Anderson,35 the Court heldthat when prison “ crowding offends the contemporary standards of humandecency,” it is per se unconstitutional under the Eight Amendment.3627647 F.2d 869, 872 (8th Cir. 1981).Id. at 872 (“In light of the legislative history of the Indian Civil Rights Act and its striking similarity to the language of the Constitution . . . weconsider the problem before us under fourth amendment standards.”). See also People v. Ramirez, 148 Cal. App. 4th 1464, 1471 (2007) (“[B]yact of Congress, Indian tribal governments have no more power to conduct unreasonable searches and seizures than do the federal and stategovernments under the Fourth Amendment.”)29In Lester, an Indian man suspected of murder on the Standing Rock Sioux Reservation was imprisoned in Fort Yates jail pending furtherinvestigation of the crime. Id. at 871-72. While incarcerated, his clothes were removed and he was given coveralls, which was said to be standardpractice at the jail. Id. at 872. Bloodstains were noticed on Lester’s clothing, so the clothing was transferred to the FBI to be inspected. Lestermotioned to suppress the clothing as evidence at his trial, arguing they were the fruit of an unconstitutional search and seizure.30621 F.Supp. 967 (D. Nev. 1985).31Id. at 970 (“This Court should not merely look at the construction of the Eighth Amendment to the U.S. Constitution. We can, however, look toconstruction under the Eighth Amendment for guidance .”).32See generally Susanna Y. Chung, Prison Overcrowding: Standards in Determining Eighth Amendment Violations, 68 Fordham Law Review(2000). 2351.33452 U.S. 337 (1981).34Id. at 352 (“The double celling made necessary by the unanticipated increase in prison population did not lead to deprivations of essential food,medical care, or sanitation. Nor did it increase violence among inmates or create other conditions intolerable for prison confinement.”).35564 F.2d 388 (10th Cir. 1977).36Id. at 395 (quoting Trop v. Dulles, 356 U.S. 86, 114 (1958).289
2) Inadequate Living Space – This is related to overcrowding, but somewhat different.Several courts have held that inadequate living space for inmates can constitute crueland unusual punishment. It has been stated that as a general rule, inmates must beafforded a minimum of 60 square feet of living space.37 This includes prisons wheremultiple inmates are housed within the same cell or unit. In the case of Ramos v.Lamm,38 the court held that it was cruel and unusual punishment to confine prisonersto cells smaller than 60 square feet and provide them less light than a thirty-footcandle would provide.393) Denationalization – In Trop v. Dulles, the Supreme Court declared that revoking acriminal’s citizenship as punishment for an offense constituted a violation of theEighth Amendment.40 It stated that denationalization results in “the total destructionof the individual's status in organized society. It is a form of punishment moreprimitive than torture, for it destroys for the individual the political existence that wascenturies in the development.”41 Thus, loss of citizenship is no longer a constitutionalform of punishment in the United States.B.The Tribal Law and Order Act’s Application of Constitutional StandardsWhen TLOA was passed in 2010, it was silent for the most part on prisoners’ rights, butit did clarify some existing ambiguities regarding the application of ICRA. As a conditionprecedent to sentencing enhancements under TLOA, a tribe must meet a number ofrequirements, namely:421) If a tribal court wishes to impose a sentence longer than one year, either:a)The defendant had to have been previously convicted of the same crime,orb)The elements of the offense are comparable to a state or federalequivalent.2) Defendants are entitled to effective assistance of counsel at least equal to thatguaranteed by the U.S. Constitution. The Sixth Amendment states that “[i]n allcriminal prosecutions, the accused shall enjoy the right . . . to have the Assistance of37See Chung, supra note 16, at 2369.520 F.Supp. 1059 (D. Colo. 1981).39Id. at 1062-63.40Trop, 356 U.S. at 104.41Id. at 101.42See M. Brent Leonhard, Umatilla’s Experience With TLOA Felony Sentencing, accessed at ce%20MBL%20ppt%20pre-conference.pdf .3810
Counsel for his defence [sic].” As stated previously, the Martinez case createdserious doubts about the jurisdiction of the federal courts to apply constitutionalEighth Amendment standards to tribes. TLOA remedied these doubts by expresslystating tribes must meet constitutional standards of effective counsel in order toemploy heightened sentencing. The leading Supreme Court case on effective counselis Strickland v. Washington.43 In that case, the Court stated that a criminal defendantmay not obtain relief on a claim of ineffective counsel under the Sixth Amendmentunless he/she can show: 1) that counsel's performance fell below an objectivestandard of reasonableness, and 2) that counsel's performance gave rise to areasonable probability that if counsel had performed adequately, the result wouldhave been different.44 Attorney counseling that meets these two standards is thusconsidered a violation of the Sixth Amendment. Therefore, under TLOA, counsel toIndian defendants in tribal courts must meet at least the Strickland standard.3) Indigent defendants must be provided counsel that is:a)At the expense of the tribe, andb)Licensed by any jurisdiction that applies appropriate professionallicensing standards and ensures competence and professionalresponsibility of lawyers. As mentioned previously, the SixthAmendment is applied to Indian tribes through ICRA; however, ICRAamends the “assistance of counsel” requirement by stating that counselshall only be provided to the accused “at his own expense.” TLOA thusfurther modifies this requirement for indigent defendants.4) Judges must be:a) Sufficiently trained to preside over criminal trials, andb) Be licensed in any jurisdiction. TLOA does not specify what sort oflicensing is required, so the presumption is that tribal licensing is just ascredible as state or federal bar licensing.5) Laws, rules of evidence, and procedures must be made publicly available, and alltribal court proceedings must be recorded in some fashion.4344466 U.S. 668 (1984).Id. at 694.11
Thus far, at least eight tribes have elected to enact the heightened sentencing protocols of TLOAand several more tribes are close to implementation. The Eastern Band of Cherokee in North Carolinaand the Confederated Tribes of the Umatilla Indian Reservation in Oregon were among the firsttribes to implement heightened sentencing protocols. Both tribes chose to participate in the BOP’sTLOA Pilot Project, which allowed for tribes to imprison criminals sentenced under the heightenedstandards of TLOA in federal prisons.45 Section 234(c) of TLOA states that the BOP shall accept aprisoner convicted by a tribal court into one of its facilities under the following conditions:46 The tribal court must petition the BOP for the prisoner’s placement by submitting arequest to the Attorney General (or a person designated to accept such a request).47 Requests for confinement must be limited to those offenders convicted of a violentcrime for which the sentence includes a term of imprisonment of two or more years. The maximum number of tribal offenders in the pilot program cannot exceed 100. The BOP’s incarceration of pilot program participants shall be subject to theconditions described in 18 U.S.C. section 5003,48 except that the offender shall beplaced in the nearest available and appropriate facility, at the expense of the UnitedStates.45Memorandum from Charles E. Samuels, Jr., Director, Bureau of Prisons, to Peter J. Kadzik, Assistant Attorney General, Office of Legislative Affairs(May 7, 2014) (on file with the National Indigenous Women’s Resource Center).46Id.47The BOP requires the following information in order to process a request and safely designate a tribal offender to the nearest appropriatefederal prison: Name; Gender; Date and place of birth; Tribal enrollment/affiliation; Offense of conviction and a description of the criminal conduct; Sentencing information; Court-ordered financial obligations (such as child support); Prior record, including descriptions of arrests and convictions; Detainers, pending charges, and outstanding warrants; Personal and family data (marital status, children, etc.); Physical, mental, and emotional health; History of substance abuse; Educational/vocational history; Gang affiliation (if applicable); Separation concerns (any person or group whom the offender must not contact); Victim information; and Current place of incarceration, including address and contact information.4818 U.S.C. § 5003 provides in relevant part that:“(a) (1) The Director of the Bureau of Prisons when proper and adequate facilities and personnel are available may contract with properofficials of a state or territory, for the custody, care, subsistence, education, treatment, and training of persons convicted of criminaloffenses in the courts of such state or territory.(2) Any such contract shall provide—(A) for reimbursing the United States in full for all costs or expenses involved;****(c) Unless otherwise specifically provided in the contract, a person committed to the Attorney General hereunder shall be subject to all theprovisions of law and regulations applicable to persons committed for violations of laws of the United States not inconsistent with thesentence imposed.” (Emphasis added.)12
It should be noted that tribal governments retain the authority to rescind their requests forconfinement of offenders imprisoned in BOP facilities at any time during an offender’ssentence.49 As of May 7, 2014, only four inmates have been lodged in federal facilities as part ofthe pilot project.50 For those tribal inmates imprisoned in federal facilities pursuant to the BOPTLOA Pilot Project, their right to be free from cruel and unusual punishment arises not from ICRA(even though they were convicted under it) but from the Eighth Amendment. Thus, TLOA hasclarified how certain constitutional standards are to be applied in Indian Country, but it has notshone much light on how cruel and unusual punishment ought to be addressed in tribal jails.4950Mem
Ed Hermes, Law & Order Tribal Edition: How The Tribal Law and Order Act Has Failed To Increase Tribal Court Sentencing Authority, Arizona State Law Journal (Summer 2013). Pg. 685. 4 year and a fine of 5,000, or both; (8) deny to any person within its jurisdiction
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