DENVER, CO – A federal appeals court has upheld the conviction of a Native American juvenile who admitted to kidnapping and assaulting a minor girl on tribal land.
In United States v. Doe, No. 25-9902, the juvenile, identified as John Doe, was found delinquent after admitting to kidnapping the girl with the intent to physically assault her. The case was prosecuted under federal law due to the crime taking place on tribal land.
Doe later appealed the conviction, arguing that his admission should be invalid because the court did not explain a legal detail clarified in a newer case. That case, United States v. Murphy, held that kidnapping charges require proof the victim was held for an “appreciable” amount of time beyond what was necessary to commit another offense.
The Tenth Circuit Court of Appeals ruled that the Murphy decision did not require reversal of Doe’s conviction. The court found no clear legal error and determined Doe’s admission was valid.
The decision was issued by a panel of the Tenth Circuit, with Judge Murphy writing the majority opinion and Judge Eid dissenting. The lower court’s judgment was affirmed.
