The Ninth Circuit has ruled that past criminal convictions in American Indian courts can't count as proof of a defendant's criminal history if defendants weren't guaranteed the right to an attorney, The Guardian reports. Michael Bryant Jr. was convicted of domestic assault in Northern Cheyenne Tribal Court but didn't have an attorney. While the Eighth and Tenth Circuits have found that tribal convictions aren't governed by the American Constitution, the Ninth Circuit has ruled that Bryant's conviction wasn't legal because the Sixth Amendment guarantees the right to an attorney.