Supreme Court of the United States
United States v. Bryant
July 7, 2016
Summary
The Supreme Court held that using prior uncounseled tribal-court convictions to establish a defendant as a habitual offender under 18 U.S.C. §117(a) does not violate the Sixth Amendment, as these convictions were valid when entered and comply with the Indian Civil Rights Act. Citing Nichols v. United States, the Court determined that convictions valid under governing law at the time of entry retain validity when invoked in subsequent federal prosecutions.
Holding
- Sixth Amendment Right to Counsel in Tribal Proceedings and Federal Enhancement. The Sixth Amendment does not prohibit the use of uncounseled tribal-court convictions as predicate offenses in federal prosecution where those convictions were valid when entered.
Docket 15-420
Cited authorities
- 18 U.S.C. §117
- 25 U.S.C. §1302
- 18 U.S.C. §117
- 119 Stat. 3077
- 18 U.S.C. §1151
- 25 U.S.C. §1301
- 119 Stat. 3077
- 119 Stat. 3077