Disparate defense in tribal courts: The unequal right to counsel as a barrier to expansion of tribal court criminal jurisdiction

Michael Bryant, Jr. was a defendant in the Northern Cheyenne Tribal Court. He pled guilty to committing domestic abuse in violation of the Northern Cheyenne Tribal Code and was sentenced to a term of imprisonment. Although he was indigent, Bryant was not appointed counsel. Meanwhile, Frank Jaimez was a defendant in the Pascua Yaqui Tribe of Arizona Tribal Court. A jury found Jaimez guilty of committing domestic violence, and he was sentenced to a term of imprisonment. Jaimez was indigent and was represented by a public defender.