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 2024-2025 Honors Program application opens on July 31, 2024, and closes on September 3, 2024. 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 2025 law school graduate should take the July 2025 bar exam unless eligible to take a spring 2025 bar exam.
Fellows must meet specific tribal court or bar admission requirements, if relevant to their assigned District.

Placement Opportunities for the 2024-2025 Indian Country Fellowship

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

District of Montana

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

Montana is a vast state with eight federally recognized tribal governments and seven Indian Reservations. The Flathead Reservation is the only PL 280 reservation, although they are urgently exploring retrocession; the other six reservations are under federal jurisdiction. They are the Blackfeet Reservation, the Rocky Boy's Reservation, the Fort Belknap Reservation, the Fort Peck Reservation, the Crow Reservation, and the Northern Cheyenne Reservation.

All credible cases alleging crimes set forth in the Major Crimes Act (18 U.S.C. § 1153), and the Indian Country Crimes Act (18 U.S.C. § 1152) are prosecuted by the USAO. Specifically, we prosecute murder, sexual abuse, kidnapping, robbery, arson, burglary, and assault cases, and we prioritize cases involving physical and sexual assaults on women and children. Typically, our Indian Country caseload accounts for approximately 1/4 of our overall annual criminal caseload. Our district also focuses upon outreach to maintain strong relationships with our Tribal and law enforcement partners. All of these duties require extensive travel. This is especially true for the Fort Peck Reservation (pop. 10,500), which is located approximately 350 miles from the federal courthouse and the USAO branch office in Great Falls.

The Fort Peck Reservation has significant violent crime involving firearms, controlled substances (including fentanyl), and sexual crimes. The Indian Country Fellow would assist in prosecuting crimes on the Fort Peck Reservation. This assistance will come through liaison work on the Reservation, law enforcement training, and attendance at our regular Multidisciplinary Team (MDT) and Sexual Assault Response Team (SART) meetings to discuss and make decisions about the treatment, investigation, and prosecution of cases. It will also come through the prosecution of federal cases.

We currently have six AUSAs who handle Indian country cases and assignments. In addition to prosecution duties, our Indian Country AUSAs have liaison point of contact duties that are vital to cultivating and maintaining our tribal and law enforcement relationships in Indian Country. Further, the AUSAs handle their own appeals.

District of Nebraska

Bar Admission Requirements: Bar admission (any State or the District of Columbia) is required for the U.S. District Court and the Omaha Tribe. In addition to bar admission, the Winnebago Tribal Code requests an application and oath, and an annual $50.00 admission fee.

The District of Nebraska is fortunate to have three Indian Reservations in the District. The Omaha Nation Indian Reservation and the Winnebago Indian Reservation sit approximately 80 miles north of Omaha, Nebraska (where the USAO’s main office is located) and are adjacent to one another. These two Reservations combined have a tribal case load that averages over 1,000 cases. The Santee Sioux Nation Indian Reservation is located 190 miles northwest of the City of Omaha and also carries a significant case load.

The three Indian Reservations have high caseloads of all sorts of crimes, particularly violent crime. There are extensive issues related to drug and alcohol use, with an increased occurrence of methamphetamine related crimes and abuses occurring. The most frequently charged offenses, in no particular order, are assault, domestic or family violence, sexual assault, child abuse, child sexual assault (many of these offenses are prosecuted by the USAO and local tribal charges are dropped), possession of controlled substances, theft, burglary, criminal mischief, disorderly conduct/disturbing the peace, driving under the influence, and minor in possession/alcohol related offenses.

The Omaha National Indian Reservation and the Winnebago Indian Reservation are the two tribes which the District of Nebraska finds the most need and foresees the most opportunity for a successful Fellow. The District of Nebraska has a strong and good working relationship with each of these tribes and the current Fellow has further fostered these relationships.

The tribes in our District, like many other tribes, are feeling the impacts of the demands on the tribal court system and not having enough resources and manpower to address them in the manner they desire to (in fact, we co-authored a request for additional law enforcement to DOJ and BIA given the dire need). The tribal courts work diligently to process cases and give them the necessary attention, but are nonetheless feeling the strain of the caseload and the very real consequences the tribal courts’ actions have on the defendants, witnesses, and victims of the crimes that occur in the tribe. We have seen the benefit and change to the processing of cases with the presence of our current Fellow and the continued contributions of a Fellow, dedicated to Indian Country, dedicated to victims, dedicated to providing the best legal advice to its tribal court community and law enforcement community, is more invaluable.

District of New Mexico

Bar Admission Requirements: Bar admission (any State or the District of Columbia) is required. The District of New Mexico anticipates its Indian County Fellow would be detailed to the Pueblo of Isleta Tribal Prosecutor’s Office. All attorneys who wish to practice in Isleta Tribal Court must submit an Attorney Application to Practice, a certificate/letter of good standing from the State Bar or Supreme Court of the state in which such lawyer is duly licensed to practice law, and a check or money order for the $500 annual fee (the Fellow would be exempt from this fee).

New Mexico, distinguished as the second most predominantly native state in the U.S., offers a vibrant tapestry of culture and heritage with the fifth largest Native American population. Home to approximately 200,000 individuals who identify as Native, this state embraces a rich diversity spanning 23 tribes, pueblos, and nations across over two million acres. The landscape of New Mexico is as diverse as its people, ranging from vast deserts to breathtaking mountains, providing an unmatched natural backdrop for both life and the practice of law. Each of these communities, while facing challenges such as higher rates of violent crime and fewer law enforcement resources compared to non-native areas, showcases unique systems of justice – sometimes utilizing local dialects of New Mexico’s myriad native languages. This complexity and cultural richness create a compelling and dynamic environment for legal practice. New Mexico not only offers enchanting beauty and a warm, inclusive community but also presents a unique professional landscape. From the historic pueblos to the expansive territories of the Navajo Nation, which extends into Arizona and Utah, and the Fort Sill Apache Tribe with lands across multiple states, the state offers a singular opportunity for young attorneys to make a significant impact while being part of a community that values deep historical roots and meaningful personal and community relationships.

In 2010, the United States Attorney’s Office for the District of New Mexico established the Indian Country Crimes Section (ICCS) to enhance public safety and fulfill its trust responsibilities within Indian Country. This dedicated section is staffed by two supervisory Assistant U.S. Attorneys (AUSAs), eleven line AUSAs, one supervisory legal administration specialist, and four legal assistants, all committed to addressing the unique challenges faced by the native communities. Additionally, the ICCS is supported by the Victim/Witness Unit, which includes six victim witness specialists and a supervisory victim witness coordinator, ensuring comprehensive support for victims. Additionally, the DOJ's dedicated Missing and Murdered Indigenous Persons AUSA for the Southwestern Region is located in our District.

The ICCS's role is particularly critical given the anticipated 18% increase in violent crime cases in Indian Country in New Mexico for 2024—a stark contrast to the national average, which remains unchanged. Our AUSAs deal predominantly with some of the most severe and emotionally challenging cases—homicides, sexual assaults, and child abuse. The geographical remoteness of many tribes and pueblos, coupled with limited police resources, poses unique challenges to our practice and underscores the need for dedicated, skilled legal professionals.

Our office is actively seeking an Indian Country Fellow to manage a full caseload amid these growing demands. This position not only offers the chance to engage in profoundly impactful legal work but also provides an opportunity to contribute to meaningful change in a community that is both underserved and deserving. Join us, and be part of a team that is not just addressing crime, but also fostering justice and healing in some of New Mexico’s most vulnerable communities. A Fellow who also practices in the Pueblo of Isleta Tribal Prosecutor’s Office will also dive in with the Tribal Court’s docket, which averages approximately five hundred fifty (550) new cases per year. Of that amount, approximately one-half or two hundred twenty-five (225) cases are criminal prosecution cases in Tribal Court. In addition, the Tribal Prosecutor’s Office handles New Mexico state felony and misdemeanor cases which originate in or have a nexus to the Pueblo. This year, Tribal Prosecutors, detailed as Special Assistant District Attorneys, have already handled almost one hundred (100) felony and misdemeanor cases in state court.

District of North Dakota

Bar Admission Requirements: Bar admission (any State or the District of Columbia) is required. Fellows would be eligible for tribal bar licensure by a simple application process

The District of North Dakota handles Major Crimes Act cases on four large Indian Reservations (Fort Berthold Indian Reservation, Spirit Lake Indian Reservation, Turtle Mountain Indian Reservation and the Standing Rock Indian Reservation, which straddles the Districts of North and South Dakota) and smaller sliver of a reservation (Sisseton Wahpeton Oyate) that extends into the District of North Dakota from the District of South Dakota.

To handle the caseloads coming off of the reservations within the district, the district has six full-time AUSA FTEs assigned with three other AUSA positions providing caseload assistance as needed. Caseloads primarily include Major Crimes such as murders, assaults, sexual assaults, burglary, robbery, child abuse and child neglect cases. Other matters include domestic violence habitual offenders, assault of federal law enforcement officers, prohibited persons in possession of firearms, possession of illegal narcotics with intent to distribute, and matters involving production/distribution/receipt/possession of images depicting the sexual exploitation of minors.

Currently the district is seeing increased caseloads coming off of the reservations and that trend is expected to continue as the BIA starts to really push recruiting to fill the many vacancies within the district. In addition, the Fort Berhold Indian Reservation, while without a licensed prosecutor at this time, is expected to become fully VAWA and TLOA compliant in the next several months to a year (they have hired a former AUSA to redraft their criminal code, rules of procedure and tribal code to allow compliance and the ability to impose sentences of up to three-years).

Fort Berthold, despite their temporary loss of a licensed prosecutor, is considered to be one of the tribal court systems that most closely matches federal, state and local courts in their process and procedure in handling criminal matters. Because of this, the District of North Dakota believes Fort Berthold would provide a tremendous opportunity for a Fellow to excel in a very modern courtroom setting.

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 Attorney General's Office.

The NDOK 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 NDOK is the home to Tulsa, the second largest city in Oklahoma, which lies within the Muscogee (Creek) Nation and the Cherokee Nation. The Cherokee Nation is the largest tribe in the United States and the Muscogee Nation is the fourth largest. The Tulsa metro population exceeds 1,000,000 making the Muscogee Nation the most populous reservation in the United States. 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 Nation; (4) Osage Nation; (5) Delaware Tribe of Indians; (6) Seneca-Cayuga Tribe: (7) Miami Tribe of Oklahoma; (8) Peoria Tribe of Indians of Oklahoma; (9) Quapaw Tribe; (10) Wyandotte Tribe; (11) Eastern Shawnee Tribe of Oklahoma; (12) Pawnee Nation; (13) Ottawa Tribe of Oklahoma; and (14) Shawnee Tribe. 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.

In FY2023, the NDOK filed 397 cases (546 defendants). Over 100 of those were Indian Country Crimes Act or Major Crimes Act cases. The cases include murders, child physical and sexual abuse, strangulation, robberies, firearms, drug trafficking, and other violent crimes. In FY2023, our office completed 27 jury trials. Since July of 2020, and the landmark Supreme Court case U.S. v. McGirt (MvO), our office has nearly doubled in size and our caseload has increased dramatically. In addition to the many Indian Country cases in our district, our office conducts several trainings to attorneys, tribal, state, and federal law enforcement, casino personnel, and child welfare workers.

Indian County in NDOK consists of at least six reservations - Muscogee, Cherokee, Quapaw, Peoria/Miami, Wyandotte, and Ottawa. In addition to the reservations, NDOK contains Indian lands that are classified as either trust land or restricted allotment land. With the 500% + increase in caseload, assistance is greatly needed in the NDOK.

The District anticipates placing its Indian Country Fellow with the Muscogee (Creek) Nation or Cherokee Nation Attorney General's Office. The Muscogee (Creek) Nation and Cherokee Nation Tribal courts serve their respective reservations. The court systems are supported by district judges, a panel of defense attorneys, and the Attorney Generals' offices. All judges and justices in the Cherokee Nation courts are attorneys. The Muscogee Nation allows for one Supreme Court justice to be a non-attorney, but must have traditional knowledge and experience.

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 July 2, 2024

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The Gaye L. Tenoso Indian Country Fellowship