Wrongly Convicted Database Record


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Michael Bryant Jr.



Assault (Domestic)


3 yrs 10 months

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Year Cleared:


U.S. State or Country of Crime:

Montana - Federal Case

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Judicially Exonerated

Summary of Case:

"Michael Bryant Jr. was wrongly convicted on February 8, 2012 of committing two counts of domestic assault by a habitual offender between February and May 7, 2011 in Birney, Montana, on the Northern Cheyenne Indian Reservation. After Bryant's motion to dismiss his indictment was denied, he pled guilty on the condition he could appeal his conviction. On May 9, 2012 Bryant was sentenced to concurrent terms of 46 months in prison on counts 1 and 2, ordered to serve 3 years of supervised release after his prison term, and ordered to pay an assessment of $200. On September 30, 2014 the Ninth Circuit Court of Appeals vacated Bryant's convictions and ordered dismissial of his indictment. Bryant was previously convicted in tribal court of domestic abuse, which the government used to establish the element of a prior offense. The Ninth Circuit held that only tribal court convictions obtained when a defendant had a right to counsel which is, at a minimum, coextensive with the Sixth Amendment right to counsel, can be used in a subsequent prosecution. Because Bryant did not have such a right to counsel during his tribal court convictions, they could not be used against him in this case and the indictment should have been dismissed. The Court stated: "Bryant’s relevant tribal court convictions do not meet this standard. Consequently, the charges against him must be dismissed." Bryant was arrested on May 24, 2011, and he was released from federal prison on August 21, 2014 after 3 years and 3 months in custody."

Conviction Caused By:

Trial judge erred by not granting Bryant's motion to dismiss his indictment.

Innocence Proved By:

"On September 30, 2014 the Ninth Circuit Court of Appeals vacated Bryant's convictions and ordered dismissial of his indictment."

Defendant Aided By:

Compensation Awarded:

Was Perpetrator Identified?

Age When Imprisoned:


Age When Released:





Information Source 1:

"USA v. Michael Bryant Jr., No. 12-30177 (9th Cir. 9-30-2014) (Vacating conviction on the basis the charged law wasn't violated.)"

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Innocents Database Created and Maintained by Hans Sherrer innocents@forejustice.org

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