United States v. Juvenile Male

Appellant is an Indian who, while a juvenile, committed an assault against another Indian within Indian country. Appellant was found to have violated 18 U.S.C. § 113 (c)(1982 & Supp. IV 1986), assault with a dangerous weapon with intent to do bodily harm. Federal courts have jurisdiction pursuant to the Major Crimes Act, 18 U.S.C. § 1153 (Supp. IV 1986). Appellant appeals his adjudication as a juvenile delinquent based on the assault.

The principal issues in this appeal relate to the interplay between the jurisdictional provisions of the Major Crimes Act and the jurisdictional provisions of the Juvenile Justice and Delinquency Prevention Act, 18 U.S.C. §§ 5031-42 (1982 & Supp. IV 1986). The Major Crimes Act provides that any Indian who commits one of a certain list of major crimes (including assault) against another Indian on an Indian reservation is subject to federal jurisdiction. Because appellant was a juvenile at the time of the crime, the special provisions of the Juvenile Justice and Delinquency Prevention Act apply. Under that Act, a judicial finding that the juvenile committed the crime does not lead to a criminal conviction, but rather to an adjudication of the juvenile…