United States v. Wheeler Case Brief
Facts:
Anthony Wheeler, the defendant was charged with disorderly conduct and contributing to the delinquency of a minor on Navajo. Wheeler was Navajo Nation member. Wheeler pled guilty and was imprisoned and ordered to pay fine by the Navajo court. After a year, Wheeler was indicted for a federal crime of statutory rape based on the same conduct which had been used to convict him in the Navajo court. However, Wheeler moved to dismiss the indictment in the federal court. In his defense, Wheeler argued that the Double Jeopardy Clause of the Fifth Amendment barred the federal government from retrying Wheeler for the crime. This is a Student Sample ORDER YOUR PAPER NOW
Rule of Law
A prosecutor’s offer is considered a unilateral contract, and as such “absent some detrimental reliance by the defendant, the State may withdraw from any plea agreement prior to the actual entry of a guilty plea.”
Issue:
Can a prosecutor legally rescind an offer to a defendant before a defendant has an opportunity to accept it?
Held:
The Double Jeopardy Clause does not bar the federal prosecution.
United States v. Wheeler Case Analysis
The United States v. Wheeler case questions the legality of the tribal courts in convicting the accused. The case was also important for the United States Supreme Court since it made it clear that Double Jeopardy does not bar the federal prosecution of the convicted person who had already been sentenced by the tribal court. The United Nations’ Article 40 on Rights of Indigenous people articulates that they have right to access and make prompt decisions through just and fair procedures for the fair resolution of conflicts and disputes. However, the tribal courts set procedures should in due consideration to the traditions, customs, rules and legal systems of the indigenous people. The role of tribal courts in the judicial process and the rule of law has been questioned when the convicted person may be charged with a lesser sentence when they have committed a serious criminal offense. In the same light; this paper uses the tribal courts and the United States v Wheeler case to explore the judicial and the Rule of Law of Double Jeopardy. This is a Student Sample ORDER YOUR PAPER NOW
Anthony Wheeler, the defendant was charged with disorderly conduct and contributing to the delinquency of a minor on Navajo. Wheeler was Navajo tribe member. Wheeler pled guilty and was imprisoned and ordered to pay fine by the Navajo court. The Tribal Court proceeding barred the federal court prosecution. After a year, Wheeler was indicted for a federal crime of statutory rape based on the same conduct which had been used to convict him in the Navajo court. However, Wheeler moved to dismiss the indictment in the federal court. In his defense, Wheeler argued that the Double Jeopardy Clause of the Fifth Amendment barred the federal government from retrying Wheeler for the crime. The District Court granted the motion, and the Court of Appeals did the same too by holding that tribal courts, and federal district courts were arms of the same sovereigns. However, this decision was later reversed by the Supreme Court. The Court held that the authority of federal government and Indian tribe sovereignty was a different and the tribal court was acting as an independent sovereign. Based on the court decision, the Double Jeopardy Clause did not bar the prosecution by the two separate sovereigns. The Court reversed the decision of the lower courts and permitted for the prosecution of Wheeler.
The Indian Tribe power to exercise fair procedures for conflict and dispute resolution had been delegated by the Congress. However, the source of its power to punish tribal offenders is questionable. The convict did not only violate the tribal customs but also went ahead and violated individual rights by raping a minor. This was statutory rape that should not be left on the hands of tribal courts but which should be dealt with according to the United States Constitution. However, the Indian tribal court possessed the sovereignty aspect that was not withdrawn by the statute, treaty or by any implication as necessary results of their dependent status. Therefore, based on this position the Navajo court was justified to bar the federal court from prosecuting Wheeler further.
Based on the treaties between the United States and Navajo tribe it was evident that the United States had established federal criminal jurisdiction over crimes with consideration of Indian tribe to prosecute the tribal offenders. This makes it clear that Navajo tribe had not lost its sovereignty and thus it had power implicitly to maintain its tribal status and exercise its power and sovereignty as a tribe. Allowing the Navajo tribe to exercise criminal jurisdiction over crimes at the tribal level it was an indication that such power was not attributable to any jurisdiction of the federal authority. This is a Student Sample ORDER YOUR PAPER NOW
As much as the Navajo tribe can exercise its sovereignty and power at the tribal level, it should be noted that when the tribe punishes a criminal member for violating tribal law or custom, the tribe does so as an independent sovereign but not as the arm of the federal government. Therefore, both the federal and tribal prosecutions belong to separate sovereignties. Based on this argument the prosecutor was justified in indicting the convict again since there was no violation of the Double Jeopardy Clause. The two sovereigns, the Navajo tribe, and federal prosecutions were not of the same offense, and thus the Double Jeopardy Clause could not bar the prosecutor from retrying Wheeler again even after the Navajo court had prosecuted, charged and ordered him to pay fine.
Even though the Supreme Court managed to clear the dual sovereignty dilemma in the United States v. Wheeler case, it brought the evident consequences of having tribal prosecutions that involved the violation of other people constitutional rights. The Navajo tribe had been permitted by the Congress to exercise criminal jurisdiction over the minor offenses. However, the Wheeler case appeared to have deprived the federal government right to enforce its own laws. This puts the legal system on the crossroads on which type of criminal prosecutions the tribal courts should undertake.
The tribal courts are not constitutional courts. For example, the Navajo Court was not a constitutional court, but a court which had been established and ordained by the Congress. The tribal courts are only mandated to deal with the minor offenses that occur at the tribal level. The Indian courts were established with the passage of Indian Reorganization Act (IRA) to enforce rules among the Indian people. These courts were only allowed to exist as a normal state of affairs since they were no official legal sanction. However, the relevance and existence of these courts became questionable with the increased interaction between the Indians and non-Indians. Increased association between the Indians and the ‘outsiders’ gives the federal government authority to prosecute the tribal court-sentenced convicts. This is because the tribal court decision might be arrived by putting into consideration the tribal customs and norms, but not the individual rights as enshrined in the constitution. Alternatively, the tribe and the federal government were two separate jurisdictions. In the same light, the United States Supreme Court found it right and justifiable to order for the retrying of Wheeler despite that he had been sentenced by the Navajo court.