The case of In re Andy, a 1956 decision of the Washington Supreme Court, demonstrated that there are approximately 15,000 persons in the state of Washington who are not amenable to criminal prosecution under state law in certain situations, and in many instances are not amenable to either state or federal prosecution. These 15,000 persons are the Indians who live in our state but who reside in "Indian country" and have retained their status as wards of the federal government. The problem of investigating and prosecuting crimes committed by these Indians has confronted and frustrated both state and federal law enforcement officers for over sixty years. It is a problem which was, until 1953, shared by at least thirteen states where, as here, Indians comprise a substantial portion of the population.
Allen L. Carr & Stanley M. Johanson,
Extent of Washington Criminal Jurisdiction Over Indians,
33 Wash. L. Rev. & St. B.J.
Available at: https://digitalcommons.law.uw.edu/wlr/vol33/iss3/3