Inside Yellowstone's 50 square mile zone of death

Yellowstone’s ‘train station’ is REAL: Inside the 50 square mile ‘Zone of Death’ where you can ‘get away with murder’ because it would be impossible to pool a jury

  • A law professor’s paper about the ‘Zone of Death’ sparked a sprawling interest in how criminal prosecution would work in the small corner of Yellowstone 
  • According to his argument, the jury drawing section of the Six Amendment could prevent prosecutors from being able to bring charges 
  • The theoretically lawless land is mentioned in several pieces of pop-culture, including runaway hit Yellowstone, where the area is used for sinister purposes  

Inside Yellowstone National Park lies a 50-square-mile swath of land where theoretically crime cannot be prosecuted and bad actors can ‘get away with murder.’

The area, dubbed the ‘Zone of Death,’ is the only part of the massive national park that bleeds into the state of Idaho.

Its breathtaking natural scenery is home to many flora and fauna but crucially, no humans. This means that if a felony crime is committed, there is no pool of people from which to draw a jury – an obligation set by a specific section of the Sixth Amendment.

The small area and its niche legal discrepancy was first brought to light when law Professor Brian Kalt wrote a paper entitled ‘The Perfect Crime’ in 2005. 

Since then, the legal loophole has inspired a host of plot lines in movies and books  – most famously in the hit TV show Yellowstone where the Dutton family regularly deposit the dead bodies of their enemies in an area dubbed ‘the train station.’

In an interview with, Kalt said his paper went ‘as viral as a law journal article can go’ – but that it was only after these pop-culture appearances that lawmakers ‘finally…took an interest in doing something about it.’

The 50-square-mile stretch of land in Yellowstone national park that stretches into Idaho has been dubbed the ‘Zone of Death’ because of the theoretical legal conundrum that the jury selection process would present if someone were accused of a crime there

Kalt’s paper is now well known that whenever there is a high-profile death in the park – such as when Gabby Petito’s body was found in neighboring Grand Teton national park – online commentators speculate if the kill took place in the ‘Zone of Death.’

The legal loophole stems from the fact that Yellowstone National Park is one of the few places in the country over which the federal government has exclusive jurisdiction and the states have none. 

The park is primarily located in Wyoming. Small parts edge into Montana and Idaho – but neither have the right to prosecute a crime that takes place inside Yellowstone’s boundaries.

In the ‘Zone of Death’ this means that if a crime were to take place, only the federal government has the ability to prosecute. 

They would then be required by the Sixth Amendment to draw a jury pool from the district and the state in which the crime was committed.

But because the ‘Zone of Death’ is in Idaho and the park falls into the District of Wyoming, a jury must be created from an area with a population of exactly zero. 

The theory goes that this means the federal government would not be able to hold a trial against a defendant and the case would be dismissed on that technicality. 

Kalt initially identified the problem in a legal paper called ‘The Perfect Crime’ that outlined the very specific circumstances under which the so-called ‘Zone of Death’ could become a lawless land.

Speaking with, Kalt said that when his paper was first released some 18 years ago, he was nervous about essentially promoting a loophole that ne’er-do-wells would look at as an opportunity to commit crime.

‘I didn’t want anyone to try to put theory into practice,’ he said.

For that reason, he asked the Georgetown Law Journal to delay the release of the paper as long as they possibly could – pushing publication from 2004 to 2005.

In the end, though, the paper does not appear to have provoked any murders. 

Instead, it attracted a good deal of attention from legal minds, politicians, and creatives. 

It’s what inspired the ‘train station’ in hit show Yellowstone – the roadside cliff where the Dutton crew deposit the dead bodies of their enemies because there is no ‘people, law enforcement, judge or jury of your peers’. 

The only difference is that this fictional spot is just past the Montana border in Wyoming rather than in Idaho. 

The specific geography of the Zone of Death means it falls in the District of Wyoming, but the state of Idaho, which creates an issue when prosecutors are tasked with drawing a jury

Michigan State University law professor Brian Kalt wrote about the legal quandary presented by the Zone of Death in a 2005 paper called The Perfect Crime that attracted significant attention from those in and outside of the legal profession

On Paramount’s runaway hit Yellowstone, the show’s main character periodically instructs his sons and ranch hands to dispose of bodies at a place called ‘the train station,’ which is based on the Zone of Death

Prior to this, best-selling author C.J. Box first used the obscure legal premise in his book Free Fall, which has subsequently been turned into the Paramount+ tv show ‘Joe Pickett.’

‘When the book came out,’ said Kalt, ‘finally someone took an interest in doing something about’ the loophole. 

In one case, that ‘someone’ was then-Wyoming Senator Mike Enzi, who became aware of the issue and unsuccessfully attempted to convince Congress to implement a quick fix that would eliminate the problem altogether.

That fix, as explained by Kalt, is simply passing a law that places Idaho’s portion of Yellowstone inside the District of Idaho. But Congress would not hear the issue, and the Department of Justice, according to Kalt, was also opposed to redrawing the district lines. 

The DOJ does not see the ‘Zone of Death’ as an imminent threat to anyone, and is essentially confident that if something did happen, they would be able to prosecute the accused anyway.

But Kalt said he doesn’t ‘think their confidence is very inspiring’ when it comes to ensuring criminals will be held accountable. 

There has been one prior instance where the legal specificities of the ‘Zone of Death’ were put to the test.

In 2005 – the year the paper came out – Michael Belderrain was charged with illegally killing two bull elk in the part of Yellowstone that crosses the Montana border.

The government attempted to have him tried in Montana but he argued that his Sixth Amendment rights would be violated by sending him out of the district in which the crime was committed (the District of Wyoming) to draw a jury.

The judge threw out the novel legal argument, saying that sending him to a more populous area amounted to a ‘harmless error.’

In terms of acting to fix the problem, Kalt said: ‘As long no one’s bleeding or losing money no one with pull in congress is going to be pushing them to do anything about it’

The ‘train station’ – a vague area referred to by the Dutton family and their confidants on Yellowstone – is an area presumed to be like the Zone of Death, where the bodies of the family’s enemies are dumped

Ultimately, the potential violation of a defendant’s constitutional rights would likely play as a pretty significant error in front of an appeals judge.

Belderrain’s case might have been a moment to test the limits of Kalt’s argument, but government attorneys sensed the same and instead offered a plea deal the accused wound up taking.

Kalt told that one stipulation of Belderrain’s plea agreement was that he specifically could not appeal his case on the grounds that his Sixth Amendment rights had been violated.

That detail makes Kalt think that the federal prosecutors were concerned about what type of ruling they might receive in front of the 10th circuit court of appeals.

He also believes that the government has, historically, been opposed to redrawing district lines because doing so would put the Montana and Idaho parts of the park into the 9th circuit court – generally understood to be a much more liberal court than the 10th circuit, into which Wyoming falls.

The DOJ was specifically concerned that environmentalist groups would bring lawsuits pertaining to the park in the more liberal – and theoretically sympathetic – court, which was not, at the time, in the government’s interest.

Kalt said that concern was illegitimate for two reasons. The first being that environmentalists were already bringing suits to the 9th circuit court about Yellowstone.  The second, is that if Congress redrew the district lines, they could specify that non-criminal cases brought about Yellowstone would have to go to the 10th circuit. 

Since his paper, Kalt has been invited to speak at Yellowstone themed legal conferences in Montana, and has been taken to Yellowstone.

He told that he’s not surprised interest in his paper and the ‘Zone of Death’ continues as ‘people are always interested in how to get away with crimes’.

He noted that the reoccurring theme of this issue, as it nears its third decade without a resolution, is that its arc in the public discourse seems to be: It would be really bad if a serious crime were to be committed in the Zone of Death, it probably won’t happen, but fixing the legal issues surrounding the area would be easy.

Unfortunately, said Kalt, ‘as long no one’s bleeding or losing money no one with pull in congress is going to be pushing them to do anything about it.’

For a  multitude of reasons, Congress and the Department of Justice have been reticent to apply the simple fix solution to the Zone of Death that would be redrawing Idaho and Montana District lines to include their parts of Yellowstone

Gabby Petito’s body was found in Grand Teton national park in Wyoming. At the time, some online spectators wondered if she had been killed or dumped in the ‘Zone of Death,’ which would have complex implications for her killer’s trial

Kalt also emphasized that since the rise of social media, which mainly happened after his paper was released, the ‘Zone of Death’ legal theory has been sensationalized and distorted.

Though the Sixth Amendment argument could one day run the government into some trouble during a prosecution, Kalt said that in reality, depending on the nature of the crime, prosecutors will likely be able to easily find a way to appropriately charge a defendant in ways that skirt the untested legal theory.

For instance, if an individual takes a victim to the Zone of Death and kills them, prosecutors may very well be able to charge the person with conspiracy and kidnapping – which would have occurred in a different state and/or district, and so on.

Sketching out what he believes may happen in the future, he said there are essentially three options.

The first – nothing will happen and the issue will go unresolved.

The second – something happens in the zone that gets Congress’ attention and they move to fix it. That option could entail someone committing a crime in the zone and going free because of the niche legal argument, or Congress being proactive after realizing that someone might commit a crime and rely on the Sixth Amendment argument.

Finally, the third option is what Kalt calls the ‘near miss possibility.’ Any time there’s a high profile crime that happens in Yellowstone, a number of people begin to wonder if it happened in the Zone of Death and it gets attention because of that.

He posits that if speculation gets annoying enough to a member of Congress, a representative from Wyoming, Montana or Idaho might eventually say ‘enough is enough’ and move to squash the problem.

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