On June 13, 2016 in its decision on U.S. v. Bryant, the Supreme Court held that uncounseled tribal court convictions that are compliant with the Indian Civil Rights Act (ICRA), are predicate offenses under the Indian Country domestic assault habitual offender statute. 18 U.S.C. §117(a). Section 117(a) was enacted in response to the deplorably high rates of domestic violence against Native American women. It provides that any person who commits domestic assault in Indian Country and has two prior domestic violence convictions in federal, state, or tribal court can be subject to federal fines, prison, or both. Click here to read the full article.