Minnesota COA Decides PL 280 Case Involving DUI on White Earth Reservation

Here is the opinion in State v. St. Clair:

State v St Clair

An excerpt:

In December 2011, a state trooper observed a vehicle traveling at 65 miles per hour in an area on the White Earth Indian Reservation where the speed limit was 55 miles per hour. The trooper initiated a traffic stop and identified the driver of the vehicle as appellant Linda Jane St. Clair. The trooper noticed that appellant’s driver’s license had an ignition-interlock restriction and asked her if an ignition-interlock device was installed in the vehicle she was driving. Appellant explained that the vehicle belonged to her husband and did not have an ignition-interlock device. The trooper cited appellant for violating her restricted license by driving a vehicle without an ignition-interlock device. See Minn.Stat. § 171.09, subd. 1(g). Appellant has six prior driving-while-impaired (DWI) convictions.

Appellant moved to dismiss the charge, arguing that the district court lacked subject-matter jurisdiction because she is an enrolled member of an Indian tribe and the offense occurred on her reservation. The district court denied the motion, determining that the state has subject-matter jurisdiction because a violation of Minn.Stat. § 171.09, subd. 1(g), is criminal/prohibitory.

The parties signed a stipulation in which appellant waived her trial rights and agreed that the district court could consider the law enforcement reports and her White Earth Reservation enrollment card. Based on the stipulated evidence, the district court determined that the state had proven beyond a reasonable doubt that appellant was guilty of violating Minn.Stat. § 171.09, subd. 1(g). This appeal follows.