United States v. John

Background

A Choctaw man, Smith John, faced both a federal indictment under the Major Crimes Act for assault with intent to kill and a state indictment for aggravated assault arising from the same incident. The federal trial resulted in a conviction of a lesser assault offense, while the state court later convicted him and sentenced him to prison. Lower appellate courts held the federal courts lacked jurisdiction because the situs of the offense was not "Indian country."

Reasoning

The central question was whether the Mississippi lands in question counted as "Indian country" under the federal definition, and if so whether federal law (the Major Crimes Act) precluded the State from prosecuting the same offense. The Court reviewed the statutory definition and prior decisions about lands set apart for Indians, and traced the history of the Mississippi Choctaws. It relied on Congress’s 1939 act placing title to certain lands in the United States in trust for Mississippi Choctaws, the 1944 proclamation of a reservation, and the band’s 1945 constitution and bylaws to conclude the lands qualified as reservation land for federal criminal jurisdiction. The Court rejected Mississippi’s arguments that long assimilation or past federal lapses eliminated federal authority.

Real world impact

Because the lands qualify as "Indian country," the Major Crimes Act supplies a federal basis to prosecute the charged offense, and the State lacks authority to prosecute the same crime on those lands. The Court reversed the Mississippi Supreme Court and the Fifth Circuit and sent the federal case back for further proceedings consistent with this ruling.