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It held, however, that Bryant’s tribal-court convictions could not be used as predicate convictions within §117(a)’s compass because they would have violated the Sixth Amendment had they been rendered in state or federal court.He was denied no right to counsel in tribal court, and his Sixth Amendment right was honored in federal court.

Bryant was denied no right to counsel in tribal court, and his Sixth Amendment right was honored in federal court, when he was “adjudicated guilty of the felony offense for which he was imprisoned.” , 535 U.In the Violence Against Women Reauthorization Act of 2013, Congress amended ICRA to authorize tribal courts to “exercise special domestic violence criminal jurisdiction” over certain domestic violence offenses committed by a non-Indian against an Indian.B This case requires us to determine whether §117(a)’s inclusion of tribal-court convictions is compatible with the Sixth Amendment’s right to counsel.§1302(a)(8), and allows tribal-court defendants to seek habeas corpus review in federal court to test the legality of their imprisonment, §1303., imprisoned for a term of not more than 5 years, or both .

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