In response to the high incidence of domestic violence against Native American women, Congress enacted a felony offense of domestic assault in Indian country by a habitual offender.
Supreme Court decision affirmed the sovereignty of Native American tribal courts and emphasized the importance of addressing domestic violence against Native women. In United States v. Bryant,the court unanimously upheld the federal conviction of Michael Bryant, Jr. as a habitual domestic assault offender, overruling a previous court’s decision.
Holding: The use of tribal court convictions as predicate offenses in a subsequent prosecution does not violate the Constitution when the tribal court convictions occurred in proceedings that complied with the Indian Civil Rights Act of 1968 and were, therefore, valid when entered.
Judgment: Reversed and remanded, 8-0, in an opinion by Justice Ginsburg on June 13, 2016. Justice Thomas filed a concurring opinion.