The U.S. Court of Appeals for the Tenth Circuit affirmed a district court's denial of a mitigating role adjustment for defendant Jasmine Rae Valdez in a federal assault case that occurred in Indian country. The decision, filed Jan. 26, 2026, highlights the stringent application of federal sentencing guidelines in cases involving crimes on tribal lands.
Valdez, also known as Jasmine Rae Rains, pled guilty to assault with a dangerous weapon in Indian country and assault resulting in serious bodily injury in Indian country under 18 U.S.C. §§ 113(a)(3) & (6). The charges also involved violations of 18 U.S.C. §§ 1151, 1152, and 2, which establish federal jurisdiction over certain crimes committed in Indian country.
The case originated in the U.S. District Court for the Eastern District of Oklahoma, where Valdez sought a mitigating role adjustment under United States Sentencing Guidelines Section 3B1.2. This provision allows for sentence reductions when a defendant played a relatively minor role in the offense or criminal activity.
The district court denied Valdez's request for the mitigating role adjustment, prompting her appeal to the Tenth Circuit. The appeals court exercised jurisdiction under 18 U.S.C. § 3742(a)(2) and 28 U.S.C. § 1291, which provide authority for appeals of certain sentencing decisions.
In an order and judgment issued by Judges Carson, Baldock, and Kelly, the Tenth Circuit panel unanimously determined that oral argument would not materially assist in resolving the appeal. The court cited Federal Rule of Appellate Procedure 34(a)(2) and Tenth Circuit Rule 34.1(G) as authority for submitting the case without oral argument.
The decision represents a typical application of federal criminal law in Indian country cases, where the federal government has jurisdiction over certain serious crimes committed on tribal lands. The Major Crimes Act and related statutes give federal courts authority over offenses like assault with a dangerous weapon when they occur in Indian country.
Sentencing Guidelines Section 3B1.2, which Valdez unsuccessfully invoked, provides for a two-level or four-level reduction in offense level depending on the defendant's role in the offense. A defendant may receive a four-level decrease if they were a minimal participant or a two-level decrease if they were a minor participant in any criminal activity.
To qualify for a mitigating role adjustment, defendants typically must demonstrate that they played a substantially reduced role compared to an average participant in similar crimes. Courts consider factors including the defendant's degree of involvement, awareness of the scope of criminal activity, and decision-making authority.
The Tenth Circuit's affirmance suggests the district court properly applied these standards in evaluating Valdez's role in the assault incidents. The appeals court did not issue a detailed opinion explaining its reasoning, indicating the panel found no clear error in the lower court's analysis.
Federal jurisdiction in Indian country cases stems from a complex web of statutes and treaties that establish when federal rather than tribal or state courts have authority. The General Crimes Act and Major Crimes Act provide the primary framework for federal prosecution of crimes involving Native Americans on tribal lands.
Assault charges under 18 U.S.C. § 113 carry varying penalties depending on the severity of the offense. Assault with a dangerous weapon and assault resulting in serious bodily injury are among the more serious forms covered by the statute, reflecting the significant harm caused in this case.
The case number 25-7045 in the Tenth Circuit corresponds to district court case 6:24-CR-00050-JFH-2 in the Eastern District of Oklahoma, indicating the original prosecution began in 2024. The relatively quick progression from district court to appeals court resolution is typical for sentencing appeals, which often involve narrow legal questions.
The court's notation that this order and judgment is not binding precedent reflects standard practice for summary dispositions. However, the decision may be cited for its persuasive value under Federal Rule of Appellate Procedure 32.1 and Tenth Circuit Rule 32.1.
For defendants in similar circumstances, the decision reinforces that mitigating role adjustments require clear evidence of a substantially diminished role in criminal activity. Courts apply these adjustments sparingly and require concrete evidence that the defendant's participation was notably less significant than that of a typical participant.
The affirmance also demonstrates the deference appeals courts typically give to district court sentencing decisions, particularly on factual determinations about a defendant's role in an offense. Absent clear error or abuse of discretion, appeals courts rarely disturb such findings.
This case adds to the body of Tenth Circuit precedent on federal sentencing in Indian country cases, an area of law that continues to evolve as courts balance federal jurisdiction with tribal sovereignty and individual defendants' rights.