A badly divided panel of the Tenth Circuit vacated the sentence of an Indian woman convicted of vehicular homicide in United States v. Lente (unpublished). She was given a sentence of 216 months, more than four times the federal guidelines upper limit.
Of note, the lower court took judicial notice of her five tribal court convictions:
The court essentially gave seven reasons for the sentence: … 3) Ms. Lente had five Tribal Court convictions and three additional arrests—most of which involved the excessive use of alcohol and violence—and these convictions, along with her five separate probations, had failed to deter her from abusing alcohol and breaking the law….
Turtle Talk 
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