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First Page

E. Supp. 1

Abstract

On July 6, 2011, in United States v. Cavanaugh, the U.S. Court of Appeals for the Eighth Circuit held that prior, uncounseled tribal court convictions could be used to establish an element of a subsequent federal offense. In so doing, the court deemphasized the importance of reliability concerns in determining the validity of uncounseled convictions.

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