the loophole. The essay, which is called "The Perfect Crime", was published in 2005 in The Georgetown Law Journal. Kalt feared that criminals might read the essay and commit a crime in the Zone before the loophole was fixed. History After Kalt discovered the loophole, he worked to have Congress close it. He suggested to lawmakers in Wyoming that the Zone of Death be included as part of the federal district court for the District of Idaho instead of the Wyoming district, which would fix the issue. However, Congress ignored Kalt's suggestion. In 2007, author C. J. Box wrote a novel called Free Fire that featured the Zone, which Box hoped would increase governmental awareness. The novel did succeed in alerting Wyoming Senator Mike Enzi to the issue. However, Enzi was unable to convince Congress to discuss it. No known felonies have been committed in the Zone of Death since Kalt's discovery. However, a poacher named Michael Belderrain illegally shot an elk in the Montana section of Yellowstone. While that section of the park does have enough residents to form a jury, it might be difficult to put together a standing and fair one due to travel or unwillingness of members of the small population there to serve. A federal judge ruled that Belderrain could be tried in the U.S. District Court for the District of Wyoming, despite the Sixth Amendment problem. Belderrain cited Kalt's paper "The Perfect Crime" to explain why he believed it was illegal to have his trial with a jury from a state other than where the crime was committed. The court dismissed this argument. Belderrain took a plea deal conditioned such that he would not appeal the Zone of Death issue to the 10th Circuit, rendering the issue moot, at least for the time being. Works of fiction Population Zero, a 2016 mockumentary about a murder in the area. In the TV series Yellowstone, enemies of the Dutton family are taken across the border into Wyoming and are executed and disposed of "at the train station". It is implied that the rules of the "Zone of Death" apply to this practice, including the location's juxtaposition with "three States" (Montana, Wyoming, and Idaho) and the lack of ability to prosecute crimes. "This is America," a 2019 episode of ABC legal drama For The People. The main plot of the novel Free Fire written by C. J.