## Facts

- Pierre Y., a Native American juvenile, lived on the Fort Peck Indian Reservation in Montana.
- On March 5, 2000, tribal police suspected Pierre of burglarizing Kae Spottedbull’s home and stealing a VCR, a Super Nintendo, and video games.
- Tribal police took Pierre into custody, contacted his mother, obtained her permission to question him, administered Miranda warnings, and had him sign a written advice-of-rights form; Pierre confessed and was released.
- On March 7, 2000, tribal police questioned Pierre at his middle school about a separate burglary involving Derek Bridges’s apartment; with his mother’s permission, police again administered Miranda warnings, obtained a signed advice-of-rights form, told Pierre he was not under arrest, and Pierre confessed.
- On March 13, 2000, the Fort Peck tribal youth court petitioned Pierre for juvenile delinquency based on the Spottedbull burglary, found him guilty, and imposed consecutive 90-day terms for theft and burglary.
- About two months later, the United States filed a federal juvenile information under the Federal Juvenile Delinquency Act (FJDA), charging two counts of juvenile delinquency based on the Spottedbull and Bridges burglaries.
- After a bench adjudication, the federal district court found Pierre committed both break-ins, adjudged him a juvenile delinquent, and ordered a 24-month custodial disposition.
- Pierre appealed, challenging federal jurisdiction and certification, double jeopardy, due process/equal protection, the denial of suppression, and the denial of a jury trial.

## Issues

1. Whether the government’s certification under 18 U.S.C. § 5032 was sufficient to confer federal jurisdiction without addressing tribal jurisdiction.
2. Whether a federal juvenile delinquency adjudication for the Spottedbull burglary violated the Double Jeopardy Clause after a prior tribal youth court adjudication for the same conduct.
3. Whether proceeding federally against a Native American juvenile subject to both tribal and federal authority violated due process or equal protection.
4. Whether Pierre’s confessions to tribal police were involuntary or obtained in violation of Miranda such that suppression was required.
5. Whether a juvenile has a constitutional right to a jury trial in an FJDA delinquency proceeding.

## Decision

- The Ninth Circuit affirmed the federal adjudication of delinquency and the 24-month custodial disposition.
- The court held the § 5032 certification was valid and did not require any statement regarding tribal jurisdiction.
- The court held double jeopardy did not bar the federal proceeding because the tribe and the United States are separate sovereigns.
- The court rejected due process and equal protection challenges to the overlapping operation of tribal and federal authority in Indian country.
- The court upheld admission of Pierre’s confessions as voluntary and preceded by valid Miranda waivers under the totality of the circumstances.
- The court held Pierre had no constitutional right to a jury trial in the federal juvenile delinquency proceeding.

## Legal Principles

- A § 5032 certification requirement is satisfied by the statutory criteria directed to state jurisdiction and does not impose an additional requirement to certify the status or adequacy of tribal jurisdiction.
- Under the dual-sovereignty doctrine, successive prosecutions (or delinquency proceedings) by a tribe and the federal government for the same conduct do not violate the Double Jeopardy Clause.
- Congressional distinctions affecting criminal jurisdiction in Indian country, including treatment of Native American offenders, are generally reviewed under rational-basis equal protection principles and may be sustained based on Congress’s authority in Indian affairs.
- Juvenile confessions are evaluated for voluntariness and Miranda waiver validity under the totality of the circumstances, including age, parental involvement, warnings given, and absence of coercion.
- There is no constitutional right to a jury trial in federal juvenile delinquency proceedings under the FJDA when the statutory scheme is otherwise constitutional.

## Conclusion

The Ninth Circuit held that federal juvenile proceedings may proceed against a Native American juvenile based on a valid § 5032 certification without tribal-jurisdiction certification, that prior tribal delinquency adjudication does not bar a later federal adjudication under double jeopardy, that the overlapping jurisdictional framework does not violate due process or equal protection, that properly warned and voluntary confessions are admissible, and that juveniles have no constitutional right to a jury trial in FJDA adjudications.


United States v. Male Juvenile, 280 F.3d 1008 (9th Cir. 2002)