The U.S. Court of Appeals for the Eighth Circuit affirmed the conviction of Nathaniel Patrick Azure on six firearms-related charges stemming from incidents on the Spirit Lake Reservation in North Dakota. The three-judge panel rejected Azure's appeal challenging the district court's denial of his motion for mistrial based on alleged prosecutorial misconduct and the admission of Facebook records as evidence.
Azure was convicted on three counts of assault with a dangerous weapon, in violation of 18 U.S.C. §§ 113(a)(3) and 1153, and three counts of discharging or brandishing a firearm during and in relation to a crime of violence, in violation of 18 U.S.C. § 924(c). The charges stemmed from three separate incidents on the Spirit Lake Reservation in North Dakota.
The first incident occurred on Jan. 6, 2021, when Azure shot Dexter Greywind. The second incident took place on May 21, 2022, when Azure allegedly pulled a gun on Lance Cavanaugh. The third incident occurred the following day, May 22, 2022, when Azure shot Daniel Cavanaugh.
Prior to trial in the U.S. District Court for the District of North Dakota, the government notified Azure of its intent to introduce his certified Facebook records related to the May 22 shooting. Azure objected to the admission of these records, arguing that the certification lacked sufficient information to verify the identity, employment, or role of Hiralys Alvarez, who was identified as the alleged Meta Custodian of Records.
The case highlights ongoing legal challenges in federal prosecutions on Native American reservations, where federal authorities have jurisdiction over serious crimes under the Major Crimes Act. The Spirit Lake Reservation, home to the Sisseton Wahpeton Oyate, has been the site of various federal law enforcement actions in recent years.
During the proceedings, Azure's defense team sought a mistrial based on claims of prosecutorial misconduct. The specific nature of the alleged misconduct was not detailed in the available court records, but the district court denied the motion. Azure subsequently appealed both the denial of the mistrial motion and the court's decision to admit the Facebook records as evidence.
The Eighth Circuit panel, consisting of Circuit Judges Smith, Kelly, and Grasz, issued a per curiam opinion affirming the lower court's decisions. Per curiam opinions are issued by the court as a whole rather than attributed to a single judge, typically used for cases that do not require extensive legal analysis or where the court's reasoning is straightforward.
The federal charges Azure faced carry significant penalties. Assault with a dangerous weapon under federal law can result in up to 10 years in prison, while the firearm enhancement charges under 18 U.S.C. § 924(c) carry mandatory minimum sentences that must be served consecutively to other sentences. The firearm charges specifically address the discharge or brandishing of a firearm during and in relation to a crime of violence.
The case was submitted to the Eighth Circuit on Oct. 20, 2025, and the court filed its opinion on Jan. 15, 2026. The opinion was designated as published, meaning it will serve as precedent for future cases within the Eighth Circuit's jurisdiction, which includes Arkansas, Iowa, Minnesota, Missouri, Nebraska, North Dakota, and South Dakota.
The admission of social media records in federal criminal cases has become increasingly common as law enforcement agencies seek to establish timelines, communications, and evidence of criminal activity. Courts must balance the probative value of such evidence against concerns about authentication and the reliability of custodial certifications from technology companies.
The Spirit Lake Reservation case underscores the complex jurisdictional framework governing criminal law in Indian Country. Under federal law, certain serious crimes committed by Native Americans on reservation lands fall under federal rather than tribal or state jurisdiction. This framework has been the subject of ongoing policy debates about tribal sovereignty and the effectiveness of federal law enforcement in addressing crime on reservations.
Azure's conviction and the appellate court's affirmation represent the conclusion of a lengthy legal process stemming from the three shooting incidents over a 16-month period. The case involved coordination between federal prosecutors, FBI investigators, and tribal law enforcement officials on the Spirit Lake Reservation.
The Eighth Circuit's decision to affirm the convictions means Azure's legal options are now limited. He could potentially seek review by the Supreme Court through a petition for certiorari, though the high court accepts only a small percentage of such requests, typically those involving significant constitutional questions or conflicts between circuit courts.
The case reflects broader challenges in federal prosecutions on Native American reservations, where communities often face higher rates of violent crime and limited law enforcement resources. Federal involvement in reservation criminal cases has increased in recent years as part of efforts to address these challenges, though tribal leaders continue to advocate for greater tribal jurisdiction and resources.