Denezpi v. United States

Merle Denezpi, a member of the Navajo tribe, pleaded guilty to an assault charge in the Court of Indian Offenses. That court is a trial court that exercises jurisdiction over Native Americans where there are no tribal courts to do so. Six months later, a federal grand jury indicted Denezpi on a charge of aggravated sexual assault based on the same underlying events. He was found guilty and sentenced to 30 years’ imprisonment.

Denezpi challenged his prosecution in federal court, arguing that it violated the Constitution’s Double Jeopardy Clause because the Court of Indian Offenses is a federal agency. The district court ruled against Denezpi, and the U.S. Court of Appeals for the Tenth Circuit affirmed.

The Court held that the Double Jeopardy Clause does not bar successive prosecutions of distinct offenses arising from a single act, even if a single sovereign prosecutes them.

Credit: Oyez, Justia Supreme Court Center, available at: https://www.oyez.org/cases/2021/20-7622