U.S. v. Little – Why Good Faith Matters

What Happened: The Story Behind United States v. Little

In 2018, state officers in Oklahoma investigated the murder of Justin Little’s wife’s boyfriend on the Muscogee Creek Reservation. At the time, Oklahoma law enforcement believed they had jurisdiction over crimes committed on Creek land. Little was arrested, tried, and later convicted of first-degree murder in federal court.

But two years after the investigation, the Supreme Court’s landmark decision in McGirt v. Oklahoma (2020) ruled that the Muscogee Creek Reservation had never been disestablished. This meant that state officers no longer had jurisdiction on Creek land, raising a major legal issue: could the evidence collected by state police, who were unknowingly out of their jurisdiction, still be used?

The Court’s Ruling: Good Faith Saves the Day

Despite the jurisdictional shift, the 10th Circuit allowed the evidence to be used, invoking the good faith exception. Here’s why:

• Long-standing belief: For decades, Oklahoma officers operated under the assumption they had jurisdiction over the Creek Reservation. It wasn’t until McGirt that this changed.

• No intentional wrongdoing: The officers acted based on the legal understanding at the time. Their actions were not deliberate violations of jurisdiction.

• Good faith exception: This legal principle allows evidence collected in good faith to be admitted, even if later found to be obtained without proper authority.

Why This Matters for Law Enforcement

1. Jurisdiction Can Shift Quickly: Major court decisions like McGirt can dramatically change the landscape of law enforcement. Officers need to stay informed about jurisdictional updates in their areas, especially when working near tribal lands or other areas with complex jurisdictional histories.

2. Good Faith Counts: Acting in good faith based on existing law provides protection, even if jurisdiction is later found to be lacking. In this case, the court ruled that excluding the evidence wouldn’t serve the purpose of deterring misconduct, as the officers acted reasonably under prior assumptions.

3. The Evolving Role of Federal and State Authority: This case underscores the dynamic nature of jurisdiction between federal, state, and tribal authorities. Officers operating in such areas must be vigilant and adaptable as legal rulings continue to evolve.

The McGirt Effect: Understanding the Broader Implications

The McGirt v. Oklahoma decision has far-reaching effects, particularly for law enforcement operating near Native American reservations. Here are some key points to keep in mind:

• Increased Federal Oversight: Serious crimes committed on tribal lands, once handled by state authorities, are now falling under federal jurisdiction. This shift may result in delays and coordination challenges between agencies.

• Retroactive Impact: Cases that were prosecuted under previous jurisdictional assumptions—like Little’s—may face legal challenges. Understanding which cases are affected is crucial for both law enforcement and legal teams.

• Federal Prosecution Process: Officers must adjust to the federal legal process when dealing with crimes on tribal lands, ensuring evidence collection aligns with federal standards.

Challenges Moving Forward

Though the ruling in United States v. Little offers some clarity, it also presents new challenges for law enforcement:

• Training and Awareness: Ensuring officers are up to date on changing legal frameworks is essential, particularly in areas with evolving jurisdictional boundaries.

• Navigating Uncertainty: As more courts address the impact of McGirt, new questions around jurisdiction may arise. Agencies need to be prepared for ongoing legal uncertainty.

Conclusion: Why This Ruling Matters for You

The 10th Circuit’s decision in United States v. Little reinforces that acting in good faith matters. Even when jurisdiction is in question, evidence gathered under a reasonable assumption of authority can still stand. As jurisdictional shifts like McGirt continue to reshape law enforcement practices, officers must stay informed, vigilant, and adaptable to ensure they operate within the bounds of the law.