This case note analyzes the Navajo Nation's application of traditional law concepts in order to find criminal jurisdiction to prosecute a non-member Indian in Means v. District Court. The author examines this use in light of the Supreme Court's decision in Duro v. Reina.
Spruhan, Paul. "Means v. District Court of the Chinle Judicial District and the Hadane Doctrine in Navajo Criminal Law." Tribal Law Journal 1, 1 (2001). https://digitalrepository.unm.edu/tlj/vol1/iss1/5