Federal Court Refuses to Suppress Statements Made to FBI under Advice of Tribal Court Lay Advocate

Here are the materials in United States v. Chase Alone (D. S.D.):

Chase Alone Magistrate R&R

Chase Alone Objection

DCT Order on Chase Alone R&R

Apparently under the Red Bird case, a tribal lay advocate is not “counsel” under the Fifth and Sixth Amendments, so any statements made to the FBI after a tribal criminal defendant is represented by a lay advocate are not required to be suppressed.