United States v. Cooley

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Supreme Court of the United States
United States v. Cooley
Term: 2020
Important Dates
Argument: March 23, 2021
Decided: June 1, 2021
Outcome
Vacated and remanded
Vote
9-0
Majority
Stephen Breyer • Chief Justice John G. Roberts • Clarence Thomas • Samuel Alito • Sonia Sotomayor • Elena Kagan • Neil Gorsuch • Brett Kavanaugh • Amy Coney Barrett
Concurring
Samuel Alito

United States v. Cooley is a case argued before the Supreme Court of the United States on March 23, 2021, during the court's October 2020-2021 term. The court vacated the decision of United States Court of Appeals for the 9th Circuit and remanded the case for further proceedings in a 9-0 ruling, holding that an Indian tribe's police officer does have authority to search and temporarily detain a non-Indian traveling on a public right-of-way that runs through Indian territory.[1] Justice Stephen Breyer delivered the opinion of the court and Justice Samuel Alito wrote a concurring opinion. Click here for more information about the ruling.

HIGHLIGHTS
  • The case: In 2016, Crow Tribe of Montana Officer James Saylor detained Joshua Cooley and searched Cooley's vehicle, which was pulled over in Indian Country on U.S. Route 212. Saylor confiscated several firearms and observed equipment that appeared to contain methamphetamine. Cooley was arrested and indicted in the U.S. District Court for the District of Montana. The district court granted Cooley's motion to suppress evidence from Saylor's search. The district court ruled Saylor acted outside of his authority by conducting an "unreasonable search and seizure" under the Indian Civil Rights Act. The U.S. government appealed, but the U.S. Court of Appeals for the 9th Circuit affirmed the lower court's ruling. The U.S. government then appealed to the U.S. Supreme Court.[2] Click here to learn more about the case's background.
  • The issue: The case concerned the scope of tribal law enforcement officers' search-and-seizure authority.[3]
  • The questions presented: Were the District of Montana and the 9th Circuit wrong to suppress evidence on the theory that an Indian tribe police officer was unauthorized to detain and search a non-Indian based on a potential violation of state or federal law while on a public right-of-way in an Indian reservation.[4]
  • The outcome: The court vacated the decision of United States Court of Appeals for the 9th Circuit and remanded the case for further proceedings, holding that an Indian tribe's police officer does have authority to search and temporarily detain a non-Indian traveling on a public right-of-way that runs through Indian territory.[1]


    • The case came on a writ of certiorari to the United States Court of Appeals for the 9th Circuit. To review the lower court's opinion, click here.

    Timeline

    The following timeline details key events in this case:

    Background

    Search and seizure

    On February 26, 2016, Officer James Saylor of the Crow Tribe of Montana was driving on a portion of U.S. Route 212 that is defined as Indian Country under 18 U.S.C § 1151. Officer Saylor saw a pickup truck on the side of the road, pulled over, and approached the truck. Joshua Cooley was in the driver's seat and was accompanied by a child. After communicating with Cooley, Officer Saylor detained him and conducted a search of the truck. Saylor confiscated several firearms and observed equipment that appeared to contain methamphetamine. He also called law enforcement officers from the county and from the Bureau of Indian Affairs (BIA) for backup. Cooley was taken to the Crow Agency Police Department, questioned, and arrested.[2]

    District of Montana's ruling

    A federal grand jury in the U.S. District Court for the District of Montana indicted Cooley on one count of possessing with intent to distribute methamphetamine and one count of possessing a firearm in furtherance of a drug-trafficking crime. Cooley moved to suppress the evidence Saylor obtained during the stop, arguing Saylor acted outside of his authority. The district court agreed, finding the Fourth Amendment of the Indian Civil Rights Act of 1968 required suppression of the evidence.[2] The Fourth Amendment of the ICRA prohibits Indian tribes from conducting "unreasonable search and seizures."[5] The district court also found that Saylor's observations before conducting the search were not enough to establish that Cooley had violated a state or federal law.[2]

    Government appeal

    The U.S. government appealed the U.S. District Court for the District of Montana's suppression order. A three-judge panel of the U.S. Court of Appeals for the 9th Circuit affirmed the lower court ruling. The government moved for an en banc rehearing. The 9th Circuit denied the motion, although three judges dissented. The government then appealed to the U.S. Supreme Court.[2]

    Indian Country

    18 U.S.C § 1151 defines Indian Country as:[6]

    “

    (a) all land within the limits of any Indian reservation under the jurisdiction of the United States Government, notwithstanding the issuance of any patent, and, including rights-of-way running through the reservation,

    (b) all dependent Indian communities within the borders of the United States whether within the original or subsequently acquired territory thereof, and whether within or without the limits of a state, and

    (c) all Indian allotments, the Indian titles to which have not been extinguished, including rights-of-way running through the same.[7]

    		”

    Questions presented

    The petitioner presented the following questions to the court:[4]

    Questions presented:
    “ Whether the lower courts erred in suppressing evidence on the theory that a police officer of an Indian tribe lacked authority to temporarily detain and search respondent, a nonIndian, on a public right-of-way within a reservation based on a potential violation of state or federal law.[7] ”

    Oral argument

    Audio

    Audio of oral argument:[8]



    Transcript

    Transcript of oral argument:

    Outcome

    In a 9-0 opinion, the court vacated the judgment of the United States Court of Appeals for the 9th Circuit and remanded the case for further proceedings, holding that an Indian tribe's police officer does have authority to search and temporarily detain a non-Indian traveling on a public right-of-way that runs through Indian territory.[1] Justice Stephen Breyer delivered the opinion of the court and Justice Samuel Alito wrote a concurring opinion.

    Opinion

    In the court's majority opinion, Justice Stephen Breyer wrote:[1]

    “ The question presented is whether an Indian tribe’s police officer has authority to detain temporarily and to search a non-Indian on a public right-of-way that runs through an Indian reservation. The search and detention, we assume, took place based on a potential violation of state or federal law prior to the suspect’s transport to the proper nontribal authorities for prosecution. We have previously noted that a tribe retains inherent sovereign authority to address “conduct [that] threatens or has some direct effect on . . . the health or welfare of the tribe.” Montana v. United States, 450 U. S. 544, 566 (1981); see also Strate v. A–1 Contractors, 520 U. S. 438, 456, n. 11 (1997). We believe this statement of law governs here. And we hold the tribal officer possesses the authority at issue.

    [7]

    		”
    —Justice Stephen Breyer

    Concurring opinion

    Justice Samuel Alito filed a concurring opinion.

    In his concurring opinion, Justice Alito wrote:[1]

    “ I join the opinion of the Court on the understanding that it holds no more than the following: On a public right-of-way that traverses an Indian reservation and is primarily patrolled by tribal police, a tribal police officer has the authority to (a) stop a non-Indian motorist if the officer has reasonable suspicion that the motorist may violate or has violated federal or state law, (b) conduct a search to the extent necessary to protect himself or others, and (c) if the tribal officer has probable cause, detain the motorist for the period of time reasonably necessary for a non-tribal officer to arrive on the scene.

    [7]

    		”
    —Justice Samuel Alito

    Text of the opinion

    Read the full opinion here.

    October term 2020-2021

    See also: Supreme Court cases, October term 2020-2021

    The Supreme Court began hearing cases for the term on October 5, 2020. The court's yearly term begins on the first Monday in October and lasts until the first Monday in October the following year. The court generally releases the majority of its decisions in mid-June.[9]

    The court issued 67 opinions during its 2020-2021 term. Two cases were decided in one consolidated opinion. Ten cases were decided without argument. Click here for more information on the court's opinions.

    The court agreed to hear 62 cases during its 2020-2021 term. Of those, 12 were originally scheduled for the 2019-2020 term but were delayed due to the coronavirus pandemic. Five cases were removed from the argument calendar.


    See also

    External links

    Footnotes

    1. ↑ 1.0 1.1 1.2 1.3 1.4 Supreme Court of the United States, United States v. Cooley, decided June 1, 2021
    2. ↑ 2.0 2.1 2.2 2.3 2.4 Supreme Court of the United States, United States v. Cooley: "Petition for a writ of certiorari," accessed November 23, 2020
    3. ↑ SCOTUSblog, "Monday round-up," November 23, 2020
    4. ↑ 4.0 4.1 Supreme Court of the United States, United States v. Cooley: "Questions presented," accessed November 23, 2020
    5. ↑ Cornell University, "25 U.S. Code § 1302 - Constitutional rights," accessed November 23, 2020
    6. ↑ Legal Information Institute, "18 U.S. Code § 1151.Indian country defined," accessed November 23, 2020
    7. ↑ 7.0 7.1 7.2 7.3 Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
    8. ↑ Supreme Court of the United States, "Oral Argument - Audio," accessed March 24, 2021
    9. ↑ SupremeCourt.gov, "A Brief Overview of the Supreme Court," accessed April 20, 2015
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