 In 1990 , the Supreme Court held in Duro v. Reina that an Indian tribe did not have jurisdiction to try an Indian of another tribe . Tribal leaders urged Congress to fix the problem that the Duro decision created . In 1991 , Congress amended the Indian Civil Rights Act ( ICRA ) to recognize that Indian tribes had inherent power to exercise criminal jurisdiction over all Indians . This legislation became known as the " Duro fix " , and was based on tribal sovereignty rather than a federal delegation of power . 
