The Tenth Circuit Court of Appeals has upheld the conviction of Ashlie Nicole Rose Martin for conspiracy to commit murder. This decision, issued on November 13, 2026, affects Martin, who was charged with orchestrating the brutal murders of her parents when she was a juvenile. The ruling is significant as it clarifies the jurisdictional authority of federal courts in cases involving crimes committed in Indian country.

The case, United States v. Martin (Docket No. 25-7057), arose from a horrific crime where Martin, an enrolled member of the Choctaw Nation, conspired with her boyfriend and a friend to kill her parents. The court's ruling not only affirms her conviction but also addresses the complex issues surrounding jurisdiction in Indian country, particularly under the Major Crimes Act.

Background

Ashlie Martin grew up in a troubled household on the Choctaw Nation Reservation in Oklahoma. At the age of 17, she convinced her then 15-year-old boyfriend, Bryson Miller, and 18-year-old friend, Chad Voyles, to murder her parents. Martin used a false pregnancy to manipulate Miller into believing that killing her parents was the only way for them to be together and raise a child.

On December 22, 2020, Martin allowed Miller and Voyles into her parents' home, where they violently attacked her mother and later her father. After the murders, they attempted to cover up the crime and fled the scene but were soon apprehended by law enforcement. The government initially charged Martin with multiple counts, including murder and conspiracy, but she ultimately pleaded guilty to the conspiracy charge in July 2023.

The case was transferred from juvenile to adult court, where the district court sentenced her to 456 months in prison. Martin appealed her sentence, arguing that it was both procedurally and substantively unreasonable, and contended that the court lacked subject-matter jurisdiction over her conviction because conspiracy to commit murder in Indian country is not an enumerated offense under the Major Crimes Act.

The Ruling

The Tenth Circuit, led by Judge Timothy Tymkovich, affirmed Martin's conviction and sentence. The court ruled that the district court had the necessary subject-matter jurisdiction over Martin's conviction. It stated, "Conspiracy to commit a murder in Indian country is a generally applicable federal crime and is therefore an offense under § 3231." This ruling clarifies that the situs of the crime is not an element of the offense, meaning that federal jurisdiction applies regardless of where the conspiracy took place.

The court also addressed Martin's arguments regarding the reasonableness of her sentence. It found that her below-guideline sentence of 456 months was neither procedurally nor substantively unreasonable. The judges noted that the district court had considered various factors, including Martin's age and psychological evaluation, before imposing the sentence.

Impact

This ruling has significant implications for future cases involving crimes committed in Indian country. It clarifies the jurisdictional authority of federal courts over conspiracy charges, even when the underlying crime occurs within tribal lands. The decision reinforces the idea that federal laws of general applicability apply equally in Indian country, which may affect how similar cases are prosecuted in the future.

Moreover, the ruling may influence how courts handle cases involving juvenile offenders, particularly regarding the application of adult sentencing guidelines. By affirming the district court's decision to impose a lengthy sentence while considering Martin's background and circumstances, the Tenth Circuit may set a precedent for how juvenile offenders are treated in serious criminal cases.

What's Next

Martin's conviction can potentially be appealed to the U.S. Supreme Court, although it is unclear if her legal team will pursue this option. There are currently no related cases pending that would directly affect this ruling. The Tenth Circuit's decision stands as a significant legal precedent regarding the jurisdiction of federal courts in Indian country and the treatment of juvenile offenders in serious crimes.