The following excerpt is from United States v. Cooley, 947 F.3d 1215 (Mem) (9th Cir. 2020):
that extends even to non-Indians on alienated fee lands. The fact that tribes lack criminal jurisdiction to try non-Indians does not mean that they must stand idly by and let non-Indians "violate the law with impunity" within the reservation. Duro v. Reina , 495 U.S. at 696, 110 S.Ct. 2053. On the contrary, a tribes sovereignty includes the authority to restrain criminal conduct within the reservation and to detain violators so that they may be prosecuted by those who do have criminal jurisdiction over them:
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