Arizona COA Vacates Gila River Member’s Conviction for Crime Committed Entirely On-Rez, Affirms Conviction for Fleeing Police

Here is the unpublished opinion in State v. Carpio (Ariz. Ct. App.):

State v Carpio

An excerpt:

Manuel Carpio appeals his convictions and sentences for one count of disorderly conduct and one count of unlawful flight from a law enforcement vehicle. Carpio, a member of the Gila River Indian Community (the Community), argues the superior court did not have subject matter jurisdiction over the disorderly conduct offense because he committed it entirely within the Gila River Indian Reservation (the Reservation). He also argues the superior court did not have personal jurisdiction because he was removed from the Reservation in violation of tribal extradition procedures after he was pursued onto the Reservation following a “hot pursuit” that began in the City of Chandler (the City). For the following reasons, we vacate Carpio’s conviction and sentence for disorderly conduct and affirm his conviction and sentence for unlawful flight from a law enforcement vehicle.

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