The following excerpt is from Shirk v. United States, 773 F.3d 999 (9th Cir. 2014):
In light of this certification regime, I think it apparent that the federal government and the tribe intended that tribal law-enforcement officers possess and exercise the power to enforce state law, both on the reservation and, in some cases, outside of it. The district court, to the contrary, concluded that the reference to peace officer certification is no more than a training requirement, imposed to ensure than all tribal officers are sufficiently qualified to meet the demands of their positions. Shirk v. United States, No. CV091786, 2010 WL 3419757, at *6, 2010 U.S. Dist. LEXIS 89687, at *15 (Aug. 27, 2010).
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