Precedents Cited

The judgment extensively references the Supreme Court's decision in SOLEM v. BARTLETT, 465 U.S. 463 (1984), which established a three-part framework to determine whether Congress has disestablished or diminished an Indian reservation. This framework examines:

1. Statutory Text: The primary source of congressional intent is the text of the statute itself. Clear language indicating disestablishment is paramount.
2. Contemporary Historical Evidence: This includes the legislative history, committee reports, and debates surrounding the statute.
3. Later History: The subsequent treatment of the reservation by federal and state authorities, and demographic changes.

The court also references Magnan v. Trammell, 719 F.3d 1159 (10th Cir. 2013), which similarly assumed AEDPA (Antiterrorism and Effective Death Penalty Act) standards apply to tribal jurisdictional claims. Additionally, the judgment discusses related cases like Indian Country, U.S.A. Inc. v. Oklahoma ex rel. Oklahoma Tax Commission, 829 F.2d 967 (10th Cir. 1987), which recognized the continued existence of the Creek Reservation.

Legal Reasoning

The court undertook a meticulous examination of whether the Creek Reservation had been disestablished or diminished. Applying the Solem framework:

1. Statutory Text: The court reviewed eight statutes passed between 1893 and 1906 related to the Creek Nation, allotment acts, and the creation of Oklahoma. None of these statutes contained explicit language disestablishing the Creek Reservation. Terms like "cede" or "relinquish," which are hallmarks of disestablishment, were absent.
2. Contemporary Historical Evidence: The court analyzed Senate debates, committee reports, and communications from the Dawes Commission. While these documents indicated a federal intent to assimilate tribes and allot lands, they did not provide unequivocal evidence that Congress intended to disestablish the Creek Reservation's boundaries.
3. Later History: Despite significant non-Indian settlement and demographic shifts within the Creek Reservation, the court found that without clear statutory language or compelling historical evidence, these factors alone do not equate to disestablishment. The continued operation of the Creek tribal government and its administrative functions further supported the reservation's intact status.

The court emphasized that only Congress has the authority to alter reservation boundaries and that in the absence of clear intent, reservations remain intact. The failure of the Oklahoma court to recognize the federal jurisdiction, based on misapplication of the Solem framework, warranted the reversal of Murphy's conviction.

Impact

This judgment reinforces the supremacy of federal jurisdiction in matters occurring within Indian country, as defined by the existing boundaries of Indian reservations. It underscores that state courts must defer to federal jurisdiction unless there is clear evidence of congressional intent to disestablish or diminish a reservation. The decision has significant implications for:

• Jurisdictional Clarity: State and federal courts must clearly understand and respect the boundaries of Indian reservations to determine appropriate jurisdiction.
• Reservation Preservation: The ruling acts as a safeguard against the inadvertent erosion of tribal sovereignty and reservation integrity.
• Future Litigation: Cases involving crimes on Indian reservations will require meticulous jurisdictional analysis, adhering strictly to the Solem framework.

Furthermore, the decision serves as a precedent within the Tenth Circuit, guiding lower courts in handling similar jurisdictional disputes involving tribal lands and members.

Indian Country

"Indian country" encompasses reservations, dependent Indian communities, and Indian allotments as defined by 18 U.S.C. § 1151. Crimes committed by Indians within these areas fall under federal jurisdiction, especially under the Major Crimes Act. Understanding these definitions is crucial in determining whether a state or federal court has jurisdiction over a particular case.

Major Crimes Act

The Major Crimes Act grants federal courts exclusive jurisdiction over certain serious crimes committed by Indians within Indian country. This means that state courts generally do not have authority to try such cases unless Congress has explicitly provided otherwise.

Solem Framework

Established in SOLEM v. BARTLETT, the Solem framework is a three-step process used to determine whether Congress has disestablished or diminished an Indian reservation:

1. Statutory Text: Analyze the wording of the relevant statute for clear indications of intent to alter reservation boundaries.
2. Contemporary Historical Evidence: Examine the legislative history, including debates and committee reports, to infer congressional intent.
3. Later History: Consider the subsequent treatment of the reservation by federal and state authorities and demographic changes to assess the reservation's status.

Only if the evidence across all three steps indicates an unequivocal intent to disestablish or diminish does the reservation lose its status as Indian country.

AEDPA (Antiterrorism and Effective Death Penalty Act)

AEDPA sets stringent standards for federal habeas corpus relief, requiring that federal courts defer to state court decisions unless they are contrary to clearly established federal law or involve an unreasonable application of state law. In this case, the court assumed AEDPA's deferential standard applied but found that the state court's decision was contrary to clearly established federal law, thus granting relief.