United States v. Little, 119 F.4th 750

Justin Little, a Native American, was investigated and arrested by Oklahoma state police in 2018 for the murder of Jonathan Weatherford on the Muscogee Creek Reservation.
At the time, state authorities believed they had jurisdiction based on longstanding precedent, but the Supreme Court’s later decision in McGirt v. Oklahoma (2020) confirmed the Creek Reservation had never been disestablished, meaning the state lacked jurisdiction.
Little was prosecuted and convicted of first-degree murder in federal court after the jurisdictional clarity provided by McGirt.
Central question: whether evidence collected by state officers acting without jurisdiction, but in good faith reliance on then-understood law, could be admitted in federal court.
The district court denied Little's suppression motion, applying the good faith exception to the exclusionary rule; Little appealed on multiple grounds including suppression, admissibility, and trial errors.

Issue	Little’s Argument	Government’s Argument	Held
Admissibility of evidence despite lack of state jurisdiction	Evidence collected by state police on tribal land should be suppressed due to lack of jurisdiction post-McGirt	Officers acted with good faith belief of jurisdiction, exclusion would not deter future similar conduct	Evidence admissible under the good faith exception to the exclusionary rule
Probable cause for arrest	State lacked sufficient probable cause to arrest him	Police had multiple witness statements, video evidence, motive	Sufficient probable cause existed for arrest
Voluntariness and admissibility of statements	Statements violated Miranda, were coerced, or police ignored request for counsel	Proper Miranda warnings given, no unequivocal invocation of counsel, no coercion	No Fifth Amendment violations, statements admissible
Admission of prior bad acts, rifle, and evidence	Prior acts and rifle were irrelevant or overly prejudicial	Prior acts relevant to motive; rifle tied to murder; relevance outweighs prejudice	No abuse of discretion in admitting prior acts and physical evidence

McGirt v. Oklahoma, 591 U.S. 894 (2020) (holding that the Muscogee (Creek) Reservation was never disestablished, limiting state jurisdiction)
United States v. Leon, 468 U.S. 897 (1984) (establishing the good faith exception to the exclusionary rule)
Herring v. United States, 555 U.S. 135 (2009) (limiting exclusionary rule to deliberate, reckless, or grossly negligent violations)
Davis v. United States, 564 U.S. 229 (2011) (exclusionary rule's deterrence rationale)
Miranda v. Arizona, 384 U.S. 436 (1966) (custodial interrogation safeguards)
Murphy v. Royal, 875 F.3d 896 (10th Cir. 2017) (holding Creek Reservation not disestablished, later affirmed in McGirt)
United States v. Pemberton, 94 F.4th 1130 (10th Cir. 2024) (applying good faith exception for state officers on reservation before McGirt)