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jurisdictionstatute

Related Cases

Ex parte Kan-gi-shun-ca, 109 U.S. 556, 3 S.Ct. 396, 27 L.Ed. 1030

Facts

The petitioner was sentenced to death for the murder of Sin-ta-ge-le-Scka, an Indian of the Brule Sioux band, in a jurisdiction that was under the exclusive authority of the United States. The conviction was affirmed by the territorial supreme court, but the petitioner argued that the district court lacked jurisdiction to try him for the crime, which he claimed was not an offense under U.S. law. The case involved complex issues regarding the jurisdiction of federal courts over crimes committed by Indians against other Indians within Indian country.

The judgment was affirmed on a writ of error, by the supreme court of the territory. It is claimed on behalf of the prisoner that the crime charged against him, and of which he stands convicted, is not an offense under the laws of the United States; that the district court had no jurisdiction to try him, and that its judgment and sentence are void.

Issue

Did the district court have jurisdiction to try the petitioner for murder, given that both the victim and the accused were members of the same Indian tribe?

It is claimed on behalf of the prisoner that the crime charged against him, and of which he stands convicted, is not an offense under the laws of the United States; that the district court had no jurisdiction to try him, and that its judgment and sentence are void.

Rule

The general laws of the United States extend to crimes committed in places under their exclusive jurisdiction, including Indian country, except for crimes committed by one Indian against another Indian.

Section 2145 of the Revised Statutes extends the general laws of the United States as to the punishment of crimes committed in any place within their sole and exclusive jurisdiction, except the District of Columbia, to the Indian country.

Analysis

The court analyzed the jurisdictional issues by examining the relevant statutes, particularly sections 2145 and 2146 of the Revised Statutes. It concluded that while the general laws applied to Indian country, the specific exception in section 2146, which excludes crimes committed by one Indian against another, remained in effect. The court found that the district court's jurisdiction was not valid in this case, as the crime fell under the exception.

The district court has two distinct jurisdictions. As a territorial court it administers the local law of the territorial government; as invested by act of congress with jurisdiction to administer the laws of the United States, in has all the authority of circuit and district courts; so that, in the former character, it may try a prisoner for murder committed in the territory proper, under the local law, which requires the jury to determine whether the punishment shall be death or imprisonment for life; (Laws Dak. 1883, c. 9;) and, in the other character, try another for a murder committed within the Indian reservation, under a law of the United States, which imposes, in case of conviction, the penalty of death.

Conclusion

The court ruled that the conviction was illegal and void due to the lack of jurisdiction, as the crime was committed by one Indian against another Indian.

But if section 2145, Rev. St., extends the act of congress, section 5339, punishing murder, to the locality of the prisoner's offense, section 2146 expressly excepts from its operation 'crimes committed by one Indian against the person or property of another Indian;' an exception which includes the case of the prisoner, and which, if it is effective and in force, makes his conviction illegal and void.

Who won?

The petitioner prevailed in the case because the court found that the district court lacked jurisdiction to try him for the murder of another Indian.

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