Choctaw Nation of Oklahoma,
Plaintiff,
VS.
Douglas Dry,
Juanita McConnell and
Rosa Burlison,
Defendants.
Case Nos. CR-95-01, CR-95-01, CR-95-03
AND CR-95-04
Defendants have filed a motion to dismiss
the charges herein on the grounds that this court does not have
subject matter jurisdiction regarding criminal matters. In response
thereto the Choctaw Nation ("the Nation") would show
to the court:
1. In 1990 the Indian Law Enforcement Reform Act 25 U.S.C. §2801
et. seq. went into effect. The act contains a provision, whereby
the Bureau of Indian Affairs could enter into an agreement with
an Indian Tribe for the tribe to provide its own law enforcement.
2. On August 14, 1991 the tribal council approved a contract between
the Nation and the United States Department of Interior ex rel
the Bureau of Indian Affairs which allowed the tribe to provide
its own law enforcement. (See attached Council Bill # CB-138-91
marked Exhibit A and the Contract marked Exhibit B.)
3. That on June 19, 1992 the tribal council, agreed to contract
with the Bureau of Indian Affairs to establish and operate a Court
of Indian Offenses pursuant to 25 Code of Federal Regulations
11. 1. A copy of the Council Bill #CB-111-92 attached and marked
Exhibit C. A copy of the Contract is attached marked Exhibit D.
4. Prior to Council Bill # CB-111-92 and the execution of the
contract referred to above the tribal court's jurisdiction was
limited to disputes involving provisions of the Constitution and
laws passed by the tribal council. However, after the enactment
of said bill and execution of the contract, the tribal court became
vested with criminal jurisdiction by virtue of these documents
not by any constitutional provisions.
WHEREFORE, the Nation requests that this court overrule the defendants'
motion to dismiss for the reasons set forth above.
I hereby certify that on the 17th day of October, 1995, I mailed a true and correct copy of the above CHOCTAW NATION'S RESPONSE TO DEFENDANTS' MOTION TO DISMISS to Scott Kayla Morrison, P.O. Box 637, Wilburton, OK 74578, with full postage prepaid thereon.