Frank v. Colville Confederated Tribes

The appellant, Mariah Frank, was charged and convicted of various crimes in three separate proceedings with three separate ease numbers. Sentencing for all convictions were combined into one criminal proceeding in which she was sentenced to consecutive terms of incarceration, the total of which exceeded one year.

The issue on appeal is whether the consecutive sentences imposed during one criminal proceeding violate the requirements of the Tribal Law and Order Act of 2010. For the reasons set forth below we hold that the Trial Court erred in its imposing, in a single criminal proceeding,…