United States v. Lara (2004)

E613636

United States v. Lara (2004) is a U.S. Supreme Court decision that affirmed Congress’s authority to recognize and expand the inherent sovereign powers of Native American tribes, particularly their power to prosecute certain nonmember Indians.

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United States v. Lara 0

Statements (49)

Predicate Object
instanceOf United States Supreme Court case
criminal law case
double jeopardy case
affirms Congress’s power to relax restrictions on tribal sovereignty previously imposed by the political branches or the Court
areaOfLaw constitutional law
criminal procedure
federal Indian law
aroseFrom Spirit Lake Tribe NERFINISHED
clarifies tribes may exercise inherent criminal jurisdiction over nonmember Indians when Congress authorizes it
concerns Congressional power over Indian affairs
Double Jeopardy Clause of the Fifth Amendment NERFINISHED
tribal criminal jurisdiction over nonmember Indians
distinguishesFrom Duro v. Reina NERFINISHED
follows Congress’s legislative response to Duro v. Reina
hasArgumentDate January 21, 2004
hasChiefJusticeAtDecision William H. Rehnquist NERFINISHED
hasCitation 541 U.S. 193
hasConcurrenceBy Anthony M. Kennedy NERFINISHED
Antonin Scalia NERFINISHED
John Paul Stevens NERFINISHED
Sandra Day O’Connor NERFINISHED
hasCourt Supreme Court of the United States NERFINISHED
hasDecisionDate April 19, 2004
hasDissentBy Clarence Thomas NERFINISHED
David H. Souter NERFINISHED
Ruth Bader Ginsburg NERFINISHED
hasDocketNumber No. 03-107
hasMajorityOpinionBy Stephen G. Breyer NERFINISHED
hasPage 193
hasPetitioner United States NERFINISHED
hasReporter United States Reports NERFINISHED
hasRespondent Billy Jo Lara NERFINISHED
hasVolume 541
hasVote 7–2
holds Congress has authority to recognize and expand the inherent sovereign powers of Indian tribes NERFINISHED
subsequent federal prosecution for the same conduct does not violate the Double Jeopardy Clause
tribal prosecution of a nonmember Indian under restored inherent authority is an exercise of tribal, not federal, sovereignty
impact strengthened recognition of inherent tribal criminal jurisdiction over nonmember Indians
interpretsStatute 1990 amendments to the Indian Civil Rights Act
25 U.S.C. § 1301(2)
Indian Civil Rights Act of 1968 NERFINISHED
jurisdiction federal question jurisdiction
legalIssue whether tribal and federal prosecutions of the same defendant for the same conduct constitute prosecutions by separate sovereigns
modifiesEffectOf Duro v. Reina NERFINISHED
relatesTo dual sovereignty doctrine
plenary power of Congress over Indian tribes
tribal sovereignty
result Eighth Circuit reversed
subjectMatter criminal assault on a federal officer on an Indian reservation

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Native American sovereignty historicallyArticulatedIn United States v. Lara (2004)