Keeble v. United States

Background

An Indian man on the Crow Creek Sioux Reservation beat his brother‑in‑law, who later died from exposure with the beating a contributing factor. The man was tried in federal court under the Major Crimes Act for assault with intent to inflict great bodily injury, convicted, and sentenced to five years. At trial he asked the judge to tell the jury they could instead convict him of simple assault, but the judge refused, and the courts below upheld that refusal.

Reasoning

The Court considered whether an Indian defendant tried under the Major Crimes Act must be denied a lesser‑offense jury instruction when the lesser offense is not one of the crimes listed in the statute. The Government conceded a non‑Indian in the same situation would get the instruction. The Court relied on the statute’s command that Indians ‘‘shall be tried in the same … manner’’ as other defendants and held the Act does not require denying a lesser‑included‑offense instruction when the evidence would rationally support it.

Real world impact

Going forward, Indians prosecuted under the Major Crimes Act may request lesser‑offense jury instructions when the evidence makes that verdict possible. The decision preserves procedural parity between Indian and non‑Indian defendants in federal trials and aims to reduce the risk of jury verdicts that convict when intent is uncertain. The Court emphasized it did not expand federal criminal jurisdiction or allow prosecution of crimes not authorized by statute.

Dissents or concurrances

A dissent argued federal courts are courts of limited jurisdiction and that giving a lesser‑offense instruction for offenses outside statutory federal jurisdiction risks invalid convictions; that view was joined by three Justices.