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SELECTED COURT DECISIONS

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In United States v. Fowler, 2022 WL 4138598 (9th Cir.

2022), Assiniboine and Sioux tribes from Fort Peck Indians

The reservation (Fort Peck Tribes) had signed

cross establishment agreement with state

Montana and various local governments that authorize state and local

law enforcement officers are replaced to enforce tribal law

on the reservation against Indians and vice versa, allowing

tribal officers are deputized there to enforce state laws. Although

driving on the highway that passes through the Fort Peck Indian

The reservation was stopped by the Indian Fowler, Montana

trooper and later charged with federal crimes based on evidence

revealed the stop. He moved to suppress on the spot that

based on the Tribe’s lack of authority to delegate authority

and other technical defects in the contract, the state ruler

he had no jurisdiction to stop him on the reservation. District

the court denied the request, and the Ninth Circuit affirmed: “[T]he

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