The Gaye L. Tenoso Indian Country Fellowship

The Gaye L. Tenoso Indian Country Fellowship, part of the Attorney General's Honors Program, is designed to create a new pipeline of legal talent with expertise and deep experience in federal Indian law, tribal law, and Indian country issues that can be deployed in creative ways to build tribal capacity, combat violent crime, and bolster public safety in Indian country jurisdictions.

The Fellowship is named in honor of the late Gaye L. Tenoso, a Department of Justice attorney whose distinguished service to the Department and the people it serves spanned 30 years. For the last six years of her life Gaye served as the Deputy Director the Office of Tribal Justice. Gaye’s expertise in Federal Indian law and knowledge of tribes enabled her to be an exceptionally effective advisor on litigation and policy matters. She worked tirelessly to ensure that specific protections for Native American women were included in the Violence Against Women Act Reauthorization of 2013. Gaye also mentored many legal interns during her time at the Office of Tribal Justice, and was an inspiration and guide who left a deep impression on many young attorneys.

Prior to serving with the Office of Tribal Justice, Gaye worked for over 25 years in the Department of Justice Civil Rights Division in the Educational Opportunities Section and the Voting Section. While in the Voting Section, she received the high honor of being invited by the United States Solicitor General to sit at counsel table during the Supreme Court argument in Reno v. Bossier Parish School District. In addition, Gaye led the Civil Rights Division’s Election Monitoring Program to ensure the right to vote for all Americans. Gaye’s passion was to ensure American Indians were provided the same access to voting as others. She was instrumental in bringing cases against counties in Arizona, New Mexico, and Utah to provide language assistance at the polls for American Indians, where she helped spearhead unprecedented remedies to provide voting opportunities for all.

Fellowship Details

Each Tenoso Indian Country Fellowship position offers a 36-month appointment that may be extended or converted to a permanent position at the hiring component’s discretion without further competition. Candidates will interview with a joint panel of attorneys from the Executive Office for U.S. Attorneys (EOUSA) and participating U.S. Attorneys' Offices (USAOs). Candidates who receive an offer of employment will be able to select their assignment preferences from the list of participating USAOs with significant Indian country work. Actual placement will be mutually agreed upon by the Fellow and the District. In addition, individual USAOs may offer additional Indian Country Fellowship positions at their discretion. This year, the Indian Country Fellowship will place one Fellow in a U.S. Attorney's Office (any participating District) with assignment based on mutual agreement of the Fellow and District.

As part of your work with a USAO, Indian Country Fellows will be required to serve 12 months with an appropriate tribal legal entity, typically in a tribal prosecutor’s office. The assignment or detail may consist of a one-year detail to a single tribal legal or governmental entity or two six-month details to different tribal legal or governmental entities.

The Indian Country Fellowship is open to all eligible Honors Program applicants, including current law students graduating in the coming academic year. The 2023-2024 Honors Program application opens on July 31, 2023 and closes on September 5, 2023. There are a few requirements associated with bar admission that applicants should consider:

Fellows who accept an offer from a USAO located in a jurisdiction that requires State bar admission must become admitted to that bar within 12 months of entry on duty.
Whether or not the USAO is located in a jurisdiction that requires admission to that State’s bar, all Indian Country Fellows hired by USAOs must be admitted to a bar (any U.S. jurisdiction) within 12 months of appointment.
Incoming Fellows who are not admitted to a bar (or who have not recently taken a bar with results pending) are expected to take the first available bar examination for which they are eligible (e.g., a May 2023 law school graduate should take the July 2023 bar exam unless eligible to take a spring 2023 bar exam.
Fellows must meet specific tribal court or bar admission requirements, if relevant to their assigned District.

Placement Opportunities for the 2023-2024 Indian Country Fellowship

(Click the link below to go directly to the participating District)

District of New Mexico

Bar Admission Requirements: Bar admission (any State or the District of Columbia) is required. The Fellow must submit proof of licensure and proof of good standing to the Pueblo of Laguna Office of the Secretary and pay an annual $100 fee before practicing in court.

New Mexico is the third most predominantly native state in the country and boasts the fifth largest Native American population. Approximately 200,000 New Mexicans identify as native. Twenty-three tribes and pueblos call more than two million acres of NM lands home. And those native communities suffer from higher rates of violent crime and lower police numbers than non-native communities. Furthermore, NM’s tribes and pueblos are diverse, employing varied systems of justice, using eight native languages, and being located across the fifth geographically biggest state in the country. Nineteen Pueblos, three Apache Tribes, and the Navajo Nation are spread throughout NM with the Navajo Nation straddling NM, Arizona, and Utah and the Fort Sill Apache Tribe with trust land in Arizona and Oklahoma as well as a reservation in southern NM.

In 2010, the United States Attorney’s Office for the District of New Mexico created the Indian Country Crimes (ICC) section to satisfy its trust responsibility of addressing justice and public safety in Indian Country (IC). The ICC section currently consists of one supervisory AUSA, nine line AUSAs, one supervisory paralegal specialist, one paralegal specialist and three legal assistants. The Section is augmented by the Victim/Witness Unit (VWU), which employs six victim advocates, including a supervisor. ICC is also supported by one part-time SAUSA from the NM Attorney General’s Office. Recently, the district was allocated an additional five ICC AUSAs, one ICC support staff position, and one regional Missing and Murdered Indigenous Persons AUSA.

According to FY23 CaseView data, the District of New Mexico filed 74 Violent Crime in Indian Country cases, compared to an average of 42.5 cases for other Southwest Border Districts, 38.9 cases in other 10th Circuit Districts, and 6.5 cases nationally (excluding New Mexico and all other Southwest Border Districts). The district ranked ranked third amongst the eight districts in the 10th Circuit and sixth in the entire country for both volume of defendants and cases filed in the Indian Country program category. So far in FY23, we have received 18 matters, 24 defendants, have 22 matters pending, and 26 defendants pending. According to a PEP report spanning May 1, 2022 until April 30, 2023, each ICC AUSA carried an average of 11.2 pending cases with an average of 15.5 new matters assigned in a 12 month period.

Our district has a critical, demonstrated need for an Indian Country Fellow. Currently, our ICC section overburns its Congressional allocation by over five AUSAs and ranks third in the nation for violent crimes in Indian Country matters received yet fifth for number of defendants charged. Current CaseView data predicts the number of violent crime matters in Indian Country to increase by 49.4% in 2023, compared to an national decrease of 7.7%. Additionally, Indian Country Crimes AUSAs have the highest percentage of violent and emotionally charged cases: homicides, sexual assaults, and child abuse.

District of Nevada

Bar Admission Requirements: Bar admission (any State or the District of Columbia) is required.

The District of Nevada intakes and prosecutes a variety of crimes under the Indian Country Crimes Act, 18 U.S.C. § 1152 and the Major Crimes Act, 18 U.S.C. § 1153. The District also prosecutes a variety of general crimes, such as drug and firearm offenses. One AUSA/Tribal Liaison in the Reno branch office is assigned to prosecute Indian Country matters exclusively. Additional AUSAs in the Reno branch office are assigned to Indian Country criminal matters as needed. AUSAs in the Las Vegas Criminal Division are assigned to criminal Indian Country matters that arise from the tribes located in the southern part of Nevada, but the majority of the Indian Country criminal matters are assigned to and handled by the AUSA/TL. The remote location of the 28 tribes in Nevada makes the case load more challenging.

Outreach to the tribes is conducted by the AUSA/TL assigned to the Reno branch office, FAUSA, and the USA. The District recognizes the need to conduct more outreach to the 28 federally recognized tribes, bands and communities located on 31 Indian reservations and colonies within the District. An Indian Country Fellow would be a force multiplier in the effort to build trust and strengthen our relationships, as well as provide much needed litigation services in both federal and tribal court. Most of Nevada is rural, often with many hours of drive time between the various Indian reservations and colonies, many located in isolated areas. A majority of the tribes are situated in the northern half of the District. To facilitate communication between the various tribes and our office, the District's Tribal Liaison AUSA has traditionally been in the Reno branch office of the USAO. The Las Vegas Paiute Tribe, Fort Mojave Indian Tribe and the Moapa Band of Paiutes are located in the Las Vegas area, and any criminal matters arising from those tribes are handled by criminal AUSAs in the District's main office in Las Vegas.

We anticipate placing the Indian Country Fellow in the Reno branch office to work directly with the AUSA/TL. The ICF detail would be to the Reno Sparks Indian Colony, which currently has a sole prosecutor carrying a caseload of approximately 150 active cases.

Eastern District of Oklahoma

Bar Admission Requirements: Bar admission (any State or the District of Columbia) is required. A Fellow would be required to be a member in good standing with a state bar in the United States and be admitted to practice in the United States District Court for the Eastern District of Oklahoma. The Fellow would also be required to become a member of the Chickasaw Bar Association and/or the Choctaw Nation Bar Association.

The Eastern District of Oklahoma (EDOK) includes 26 counties in the State of Oklahoma. Significantly, the EDOK contains the headquarters of the Five Civilized Tribes (Cherokee, Choctaw, Muscogee (Creek), Chickasaw and Seminole Nations). As a result of the SCOTUS decision in McGirt v. Oklahoma and subsequent opinions from the Oklahoma Court of Criminal Appeals, the entire EDOK is Indian Country. Consequently, the USAOKE has experienced a massive increase in violent crime case referrals. Since August 2020, the USAOKE has received 6,985 Indian Country case referrals and opened 1,417 matters in CaseView for potential federal prosecution. Currently, the USAOKE has 581 active violent crime in Indian Country (VC/IC) cases including 128 murder investigations. Since November 2020, the EDOK has had over 80 felony jury trials. The vast majority of those were VC/IC matters including 26 Murders, 23 Aggravated Sexual Abuse and 10 Sexual Assault.

An Indian Country Fellow (ICF) would be invaluable in assisting the USAOKE in liasioning with the Five Tribes, but especially the Choctaw Nation and Chickasaw Nation in the EDOK while navigating the sea change in jurisdiction. The USAOKE is receiving case referrals from law enforcement agencies within each of the Five Tribes. Having an ICF would allow the USAOKE and the tribes to coordinate case referrals and prosecution of crimes involving Native American suspects and/or Native American victims in both federal and tribal court.

Northern District of Oklahoma

Bar Admission Requirements: Bar admission (any State or the District of Columbia) is required. Tribal bar admission may be required, but that may be obtained after appointment, provided Fellow's bar admission is in good standing. Fees are generally waived by the tribe. We anticipate detailing the Fellow to the Muscogee (Creek) Nation or Cherokee Nation.

In 2022, the NDOK filed 211 Indian Country cases, including murders, child physical and sexual abuse, strangulation, robberies. and other violent crimes. We currently have over 30 homicide cases pending. Since July of 2020. and the landmark Supreme Court case U.S. v. McGirt, our office size and caseload has increased drastically. Of the 68 AUSAs in the NDOK, 38 are solely assigned to Indian Country crimes. Our office annually conducts several trainings to attorneys, tribal, state, and federal law enforcement, casino personnel, and child welfare workers.

The Northern District of Oklahoma lies entirely within the area formerly known as Indian Territory. The site of the forced removal of several tribes, Oklahoma has a very diverse and unique history. The Northern District of Oklahoma is the home of the second largest city in Oklahoma, Tulsa. NDOK encompasses eleven counties in the northeastern part of Oklahoma. Located within the District are fourteen Federally recognized tribes: (1) Cherokee Nation; (2) Muscogee (Creek) Nation; (3) Modoc Tribe; (4) Osage Nation; (5) Delaware Tribe; (6) Seneca-Cayuga Tribe; (7) Miami Tribe; (8) Peoria Tribe; (9) Quapaw Tribe; (10) Wyandotte Tribe; (11) Eastern Shawnee Tribe; (12) Pawnee Nation; (13) Ottawa Tribe; and (14) Shawnee. Oklahoma has the second highest American Indian/Alaska Native population (12.9%), second only to Alaska. Each tribe has their own government, some resembling the federal government's structure and some based more on historical structures. The USAO is committed to maintaining a government-to-government relationship with each of these tribes, and striving to meet the Federal trust responsibility with regard to justice issues. Throughout the District exists various types of Indian Country, as defined in Title 18, United States Code, Section 1151. Indian County in NDOK consists of at least three reservations - Muscogee (Creek) Nation, Cherokee Nation, and Quapaw Tribe. The Muscogee (Creek) Nation is the most populous reservation in the Nation with a population of over 500,000 people. In addition to the reservations, NDOK contains Indian lands that may be classified as either trust land or restricted allotment land. With the 500%+ increase in caseload, assistance is greatly needed.

Western District of Oklahoma

Bar Admission Requirements: Bar admission (any State or the District of Columbia) is required. Fellows may have to satisfy additional, modest requirements to practice in Tribal courts.

The Western District of Oklahoma has the lands of 21 distinct federally recognized tribes spread checkerboard fashion throughout the district, with hundreds of thousands of acres of allotted Indian land and tribal trust land. In addition to the thousands of parcels of allotted and tribe trust lands for 20 tribes, approximately one half of the Chickasaw Nation, including all lands within five counties are located within the Chickasaw Reservation’s boundaries. Since Public Law 280 has no application within Oklahoma, the U.S. Attorney’s Office has full criminal jurisdiction over all Major Crimes Act crimes committed by Indians, as well as crimes committed by Indians v. non-Indians and Non-Indians v. Indians under the Indian Country Crimes Act. Also, because the State of Oklahoma does not have jurisdiction over Indians, the U.S. Attorney’s Office has jurisdiction over Indian victimless crimes, including DUIs and other traffic offenses within the five counties of the Chickasaw Nation located in the District, as well as on the allotted and tribal trust lands of the remaining 20 tribes. The largest acreages of allotted and tribal trust land includes the Cheyenne-Arapaho Tribes and the Kiowa, Comanche, & Apache Tribes which have concurrent jurisdiction over lands spread over five counties. There are scores of tribal casinos and large tribal businesses (hotels, motels, supermarkets, etc.) in the Western District of Oklahoma, therefore there are large numbers of non-Indians within Indian country, placing primary responsibility for prosecution with the U.S. Attorney’s Office when major crimes occur by or against Indians.

Because of the large number of tribes in the District and the relatively high population of Native Americans in the State of Oklahoma generally, there are many criminal matters requiring federal prosecution. While the Chickasaw Nation has a large and sophisticated court system, many of the other tribes in the District have limited ability to prosecute crime given their limited resources and small tribal justice systems, such as the Comanche Nation and the Cheyenne-Arapaho Tribes. Presently six tribes do not have their own tribal court systems and are served by the Court of Indian Offenses, operated by the Bureau of Indian Affairs. Because of the number of tribal casinos and extent of tribal businesses and casino operations, there is a fair amount of white collar crime involving tribal employees or assets. There is also a significant amount of drug possession at tribal casinos, which has been addressed by utilization of the District’s Central Violation Bureau (“CVB”) Indian Country docket as well as the District Court when trafficking is involved. Many of the line AUSAs handling Indian country cases are involved with prosecuting crimes from the lands of all of the 21 tribes in the District.

District of Oregon

Bar Admission Requirements: State Bar admission (any State or the District of Columbia) is required. The Fellow must become admitted to the bar of the Umatilla Tribal Court. To be eligible, the Fellow must be a member in good standing of any tribal or State bar, petition for admission, and file an admission fee of $100.00.

The District of Oregon has a significant Indian Country criminal caseload, including violent crimes (homicide, sexual assault, domestic violence, gang assaults, and firearms offenses), drug trafficking organizations, and fraud/embezzlement cases. The District’s Major and General Crimes Act jurisdictional authority is focused on four tribal governments – Burns Paiute Tribe, the Confederated Tribes of the Umatilla Indian Reservation (CTUIR), the Confederated Tribes of Warm Springs, and the Cow Creek Band of Umpqua Tribe of Indians. The criminal jurisdiction regarding the remaining five (5) tribes (the Confederated Tribes of the Coos, Lower Umpqua & Siuslaw Indians; Coquille Indian Tribe; Confederated Tribes of Grand Ronde; Klamath Tribes; and Confederated Tribes of Siletz Indians) is impacted by Public Law 280.

The Indian Country Fellow would work on a wide variety of cases in the U.S. Attorney’s Office in Portland, Oregon as well as with the CTUIR Tribal Prosecutor in the CTUIR Tribal Court. The District of Oregon has a Tribal Special AUSA (SAUSA) on Indian Country cases involving sexual assault, domestic violence, dating violence, stalking and sex trafficking linked to intimate partner violence. The Tribal SAUSA serves as the CTUIR Tribal Prosecutor. The Indian Country Fellow would have the opportunity to complement the Tribal Prosecutor’s work, as well as covering other types of cases in Tribal and Federal Court. The CTUIR began asserting VAWA’s “Special Domestic Violence Criminal Jurisdiction” in 2014 and recently enacted VAWA 2022’s “Special Tribal Criminal Jurisdiction” on October 1, 2022 to exercise expanded non-Indian criminal jurisdiction. The Tribe’s assertion of Special Domestic Violence Criminal Jurisdiction has improved the tribal justice system, granting Tribal Courts tougher sentencing powers for crimes, and expanding coordination between federal agencies and the tribal justice system. The Indian Country Fellow would work closely with the AUSA and the Tribal Prosecutor in organizing periodic training and case reviews with the Umatilla Tribal Police Department.

The District of Oregon’s Tribal SAUSA position is dedicated to crimes taking place on the CTUIR reservation and is focused on investigation and prosecution of Indian Country cases involving sexual assault, domestic violence, dating violence, stalking and certain sex trafficking cases linked to intimate partner violence. The Indian Country Fellow would spend one year or two six month terms at the CTUIR Tribal Prosecutor’s Office complementing the Tribal SAUSA’s work by covering other aspects of prosecution. Thus, the Indian Country Fellow would have an unparalleled opportunity to try cases in two excellent trial settings, federal court and CTUIR Tribal Court, supported by enthusiastic and knowledgeable coworkers and team members. The Indian Country caseload in the District of Oregon caseload is as intense and interesting as any jurisdiction in the country and will provide the recipient of the Indian Country Fellowship a challenging and rewarding experience.

Finally, the Indian Country Fellow could work to develop a library of protocols, pleadings, and memos around victim rights for Indian Country cases. Most of the federal cases handled by the USAO are victim cases. The Tribal Victim Assistance Specialist position allows the utilization of victim rights statutes to enhance legal and physical safety protections for the vulnerable victims out of these cases. The Indian Country Fellow would research utilizing victim rights in enhancing victim safety in federal cases, and develop standard pleadings and memos to place victim safety at the forefront of Indian Country cases.

The Indian Country Fellow would also work with tribal officers in charging, negotiating and trying federal misdemeanor cases in the U.S. Magistrate Court in Pendleton, Oregon, on a bi-monthly basis. The United States District Court for the District of Oregon approved a CVB collateral schedule for Indian Country, enabling tribal officers to cite non-Indians for specified misdemeanors on tribal lands. The Indian Country Fellow would work closely with Portland-based AUSAs in supervising law clerks who appear on some of these matters, as well as in developing appropriate training in investigation and court appearances for the tribal officers issuing CVB citations.

When working in the Portland office, the Indian Country Fellow will have the opportunity to serve as a second chair in appropriate Indian Country felony trials, and possibly lead counsel as the Fellowship progresses. The Fellow will also have the opportunity to work on cases from the CTUIR, the Warm Springs Reservation, the Burns Paiute Reservation, and the Cow Creek Band of Umpqua Tribe of Indians.

Indian Country cases often involve some of the most vulnerable victims; institutional racism and disenfranchisement, intergenerational trauma, poly-victimization, addiction, and poverty in many of these cases combine to be seemingly insurmountable barriers to safety. The USAO has a need for an attorney to explore utilizing victim rights statutes and streamlining victim protection efforts via the legal system for our most vulnerable victims.

Eastern District of Washington

Bar Admission Requirements: State Bar admission (any State or the District of Columbia) is required. Fellows may have to satisfy additional, modest requirements to practice in Tribal courts. We anticipate the Fellow would be embedded in the Yakima or Colville Tribe. The U.S. Attorney’s Office (USAO) would support the Fellow in seeking admission with the respective Tribal court.

The USAO for Eastern District of Washington’s main office is located in downtown Spokane, overlooking the Spokane Falls. The Spokane Office serves the Confederated Tribes of the Colville Indian Reservation, the Spokane Tribe of Indians, and the Kalispel Tribe of Indians. While these Tribal Nations are 1-2 hours from the Spokane Office, frequent travel generally is not necessary. Our Yakima Office is located in the Yakima Valley, in the shadows of Mount Rainier and Mount Adams and serves the Yakama Nation, which is minutes away from their office and the Yakima Federal Courthouse.

The USAO has an extensive Indian Country caseload and presence. Both the Spokane Main Office and the Yakima Branch Office have multiple pending cases arising in Indian Country, including murder charges, violent assaults, child abuse, child exploitation, cyberstalking, domestic violence, sexual assault, kidnapping, drug offenses, firearms offenses, and burglary and robbery matters. At the present time, there are more than 100 active cases arising in Indian Country in the Eastern District of Washington.

The cases prosecuted in Eastern Washington are diverse and demonstrate the USAO’s commitment to ensuring justice on behalf of all victims, including in cases arising in Indian Country. In doing so, we seek to prioritize the most serious cases involving victims of violent crime. Both the Spokane and Yakima offices are prosecuting several homicides occurring in Indian Country, involving both Indian and non-Indian victims. Historically, these serious cases are more likely to proceed to trial, and our offices have several skilled prosecutors with extensive trial experience to train and support a Fellow. Just last year, after a challenging and complex trial, a federal jury in Spokane found an enrolled member of the Yakama Nation guilty of, inter alia, four first degree murders, kidnapping of a minor, and carjacking. We have also seen an increase in serious crimes committed by juveniles on the Yakama Nation, including homicide, attempted homicide, and rape. Our offices have specialized expertise in the complex prosecution of juveniles in the federal system, and a Fellow would have the unique opportunity to participate in seeking justice in these critical cases.

A Fellow who serves in the Eastern District of Washington will immediately become part of the USAO team, and he or she will take on responsibilities similar to those of an Assistant United States Attorney. The Fellow would serve in a hybrid role – prosecuting cases for the USAO on behalf of one or more tribes. The USAO will provide the Fellow with robust training opportunities, both locally and through the National Advocacy Center. The USAO has a mentoring program designed to ensure new attorneys have the resources they need to succeed in the various phases of criminal prosecution. Upon successful completion of the fellowship, the USAO may offer the Fellow a permanent position as an Assistant United States Attorney without further competition.

The USAO for the Eastern District of Washington values its reputable relationship with tribal law enforcement for each of the four Tribal Nations in the Eastern District. This relationship has served to benefit the District greatly, and has resulted in robust caseload in both the Spokane and Yakima offices.

The USAO is committed to building safer and stronger communities in the Eastern District of Washington. Our District recognizes that Native Americans experience some of the highest rates of violence in the country, a situation that is all the more tragic in light of the generations of trauma already suffered by Indigenous people. We also recognize the general trust relationship between the United States and the Tribes, and we continually seek to do our part to prosecute violent offenders who jeopardize the public safety of tribal communities in Eastern Washington.

Updated June 27, 2023

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The Gaye L. Tenoso Indian Country Fellowship