How did United States v. Wheeler address tribal prosecution and double jeopardy?

In United States v. Wheeler (1978), the U.S. Supreme Court addressed the intersection of tribal sovereignty and the constitutional protection against double jeopardy. The case involved a member of the Navajo nation who argued that being prosecuted in federal court for a crime for which he had already been convicted in a tribal court violated his rights against being tried twice for the same offense.1

The Supreme Court ruled against the defendant, affirming that tribal courts and federal or state courts are distinct judicial entities. The Court determined that because a tribe exercises its own inherent sovereignty when prosecuting its members, its judicial proceedings are separate from those of the United States. Consequently, the double jeopardy clause does not bar a federal or state government from prosecuting an individual for the same criminal act for which they have already been tried by a tribal nation. This decision established that Indigenous individuals can be subject to prosecution in both tribal and federal or state courts for a single act, a legal reality that contrasts with the immunity from tribal prosecution granted to non-Indigenous individuals in Oliphant v. Suquamish Indian Tribe.1