United States v. Bryant

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.