United States, Petitioner v. Michael Bryant, Jr.

Summary

The Court held that uncounseled tribal-court convictions compliant with the Indian Civil Rights Act may be used as predicate offenses in a prosecution under 18 U.S.C. § 117(a). Because the Sixth Amendment does not apply to tribal courts, these convictions were valid when entered and remain valid when invoked later. Justice Thomas concurred, noting doubts about the underlying precedents regarding tribal sovereignty and the Sixth Amendment.