Should you take train station exit 76

The Train Station, also referred to as the Long Black Train, is a rural canyon area past the Montana border into Wyoming. It is the area where the Duttons and the branded execute and/or dispose of their enemies and those who know many of Yellowstone’s secrets. As Lloyd Pierce pointed out, it is a county consisting of no people, no law enforcement, no judge and jury of your peers, and no one living within a hundred miles. This area is an example of how the west was won.

The concept of The Train Station is based on the real-life “Zone Of Death”, the 50-square-mile portion of Yellowstone National Park within Fremont County, Idaho (and to a lesser extent, the portions of the park within Gallatin and Park Counties in Montana) where, due to a legal loophole stemming from a conflict of judicial district boundaries versus state boundaries and the United States Constitution, it is technically legal to get away with murder, or any other crime, due to the inability to assemble a jury from residents from the same county and jurisdiction of the area where the crime was committed.

As Yellowstone National Park is federally managed land, any crimes that occur within the park are automatically sent to federal court. The federal district that handles crimes committed within Yellowstone, by law, is the District of Wyoming. Since the park boundaries extend slightly into Idaho and Montana, the District of Wyoming is the only federal court district that has jurisdiction over parts of multiple states, and crimes committed in the park are tried at the federal courthouse in Cheyenne. However, the Constitution of the United States states, in no less than three separate places, the right to suspected criminals to have a jury trial (Article III, Section Two, Sixth Amendment, Seventh Amendment). In particular, the Sixth Amendment states “the accused shall enjoy the right to a speedy and public trial, by an impartial jury of the State and district wherein the crime shall have been committed [emphasis added]”. As there is nobody living within the 50 square mile-Idaho portion of the park, and because the federal courthouse with jurisdiction over that section of the park is in another state, a jury could not be legally empaneled. Thus, theoretically, crimes committed in the Idaho portion of the park, and also the Montana portion, could not be legally prosecuted in court, regardless of guilt or innocence.

This theory was discovered in 2005 by Brian C. Kalt, a law professor at Michigan State University; Kalt discovered the issue while researching a paper about technicalities within the Sixth Amendment. Horrified by the discovery, Kalt immediately tried to bring attention to the issue to resolve it, writing a paper titled “The Perfect Crime”. He brought the issue to Congress, proposing that they fix the loophole by transferring jurisdiction of the areas of Yellowstone National Park outside Wyoming to their respective states, and while he did get the attention of Wyoming State Senator Mike Enzi and Wyoming author C.J. Box (whose novel, Free Fire, was deliberately written to raise awareness to the issue), Congress failed to take action. However, while no known murders have actually taken place, a man named Michael Belderrain got busted for elk poaching south of Gardiner, Montana, inside the park, and was tried in the District of Wyoming for it; Belderrain cited Kalt’s paper in his defense. Belderrain took a plea deal in which he promised not to appeal the “Zone of Death” issue to the 10th Circuit Court of Appeals, rendering the issue moot, for now.

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