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2001: Nevada v. Hicks (2002) 121 S. Ct. 2304

The decision relied on two previous rulings, Montana v. U.S. and Oliphant v. Suquamish Indian Tribe. The Supreme Court held that the tribal court did not have jurisdiction to adjudicate state officials conduct in executing a search warrant to a tribal member for an off reservation crime. More importantly, the Supreme Court in regards to the jurisdictional reach of tribal courts over non members, stated: "...tribal courts, it should be clear, cannot be courts of general jurisdiction in this sense, for a tribe's inherent adjudicative jurisdiction over non members is at most only as broad as its legislative jurisdiction." Id. At. 2314." Absent a federal law providing tribal court jurisdiction over a particular cause of action, tribal courts lack jurisdiction to adjudicate actions over non-tribal

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