Three defendants, Uriah Waggerby, Sylvanis Brice, and Johan Holder, conspired to rob Reuben Billie, Jr., a marijuana dealer, at his home on the Big Cypress Seminole Indian Reservation. During the robbery, a bystander was shot and killed, though the defendants fled without stealing anything. The defendants were charged with conspiracy to commit Hobbs Act robbery and attempted Hobbs Act robbery. Waggerby moved to dismiss the indictment, arguing that federal courts lacked jurisdiction because he and the victim were enrolled tribal members and the crime occurred in Indian country, and the Hobbs Act was not listed in the Major Crimes Act. During trial, the government introduced evidence of Brice's prior convictions to impeach his credibility after he made exculpatory statements. The district court admitted the prior convictions without conducting the required on-the-record balancing test. The jury convicted the defendants, leading to this appeal.
The court addressed two primary issues. First, regarding jurisdiction, the court distinguished between federal enclave statutes, which apply only in specific federal territories, and generally applicable federal laws. The Indian Country Crimes Act extends enclave laws to Indian country but excludes Indian-on-Indian crimes. The Major Crimes Act creates an exception to that exclusion for specific enumerated offenses like murder or robbery under state law. However, the court held that the Major Crimes Act does not limit federal jurisdiction over generally applicable federal statutes, such as the Hobbs Act, which apply to all persons regardless of location or identity. Citing Supreme Court precedent, the court reasoned that general statutes include Indians and their property interests. Therefore, federal courts have jurisdiction over Hobbs Act violations committed by Indians against Indians in Indian country. Second, regarding the evidence of prior convictions, the court acknowledged that the district court erred by failing to make an on-the-record finding that the probative value of the evidence outweighed its prejudicial effect. However, applying the harmless error standard, the court found the error did not affect the outcome. The government presented strong independent evidence, including Brice's own recorded confession detailing the crime, ballistics evidence corroborating his account, and cell site records placing him at the scene. This evidence was sufficient to support a conviction even without the prior convictions.
This decision clarifies that the Major Crimes Act does not create a jurisdictional shield for Indian defendants against generally applicable federal criminal laws like the Hobbs Act. Prosecutors can pursue federal charges for such crimes in Indian country regardless of the tribal status of the perpetrator and victim. Additionally, while the ruling reinforces the procedural requirement for district courts to perform an on-the-record balancing test before admitting prior conviction evidence, it confirms that failure to do so will not automatically result in a reversal if the remaining evidence of guilt is overwhelming.