In Oklahoma v. Castro-Huerta, 2022 WL 2334307 (US
2022), the Supreme Court addressed the General Crimes Act, 18
U.S.C. 1152, which, "[e]xcept as otherwise expressly provided
by law," extends the "general laws of the United
States" to "the Indian country." The State of
Oklahoma prosecuted and convicted Castro-Huerta, a non-Indian
residing in Tulsa, for criminal neglect of his step-daughter, a
Cherokee Indian. Castro-Huerta challenged his conviction on the
ground that, pursuant to the Supreme Court's 2020 holding in
McGirt v. Oklahoma, the site of the offense was Indian
country, and the state lacked jurisdiction under the General Crimes
Act. The Supreme Court disagreed, holding that the state and
federal governments had concurrent jurisdiction over offenses
committed in Indian country by non-Indians against Indians:
"Indian country is part of the State, not separate from the
State. To be sure, under this Court's precedents, federal law
may preempt that state
