After his conviction, Murphy filed an application for post-conviction relief in an Oklahoma state court seeking to overturn his conviction by claiming the federal government had exclusive jurisdiction to prosecute murders committed by Indians in Indian country; Henryetta lies within the former boundaries of the Moscogee reservation. The state district court concluded state jurisdiction was proper because the crime had occurred on state land. Murphy appealed to the Oklahoma Court of Criminal Appeals which also determined that the state had jurisdiction. Murphy then sought habeas relief in the Federal District Court of Eastern Oklahoma. The Federal District Court determined the Oklahoma state court decisions were not contrary to federal law and denied the habeas petition. Murphy then appealed to the Tenth Circuit, which reversed the decision of the District Court. The Tenth Circuit found no prior court had reviewed whether Congress disestablished the Muscogee reservation under the tests of Solem v. Bartlett (1984), a prior case that established that only Congress has the power to disestablish native reservations. On its own analysis of all laws passed by Congress related to the tribal reservation and Oklahoma's statehood, found no explicit statement of disestablishment. The Tenth Circuit also found that other acts of Congress around the time still treated the reservation as if it were Indian-owned land, contrary to the disestablishment intent if that had occurred. Thus, the Tenth Circuit ruled in favor of Murphy that he should have been prosecuted under federal jurisdiction.
