witnessed as a child—which included the shooting of his grandfather in the throat, the shooting of his uncle with a gunshot, and the shooting death of his cousin. 2 . The district court concluded that the defendant's "social background in many ways [wa]s not markedly different from that of hundreds of other youngsters who grow up on Montana’s Native American reservations, and who never resort to violent and destructive behavior of the sort disclosed by the record in this case.” 3 . Because of the structure of the FJDA, Native American youth are disproportionately subject to federal court jurisdiction for their delinquency offenses. This court has therefore noted that a defendant's status as Native American may merit special consideration. Juvenile, 347 F.3d at 789 n. 10 (9th Cir.2003) (<HOLDING>). However, this court has never suggested that
holding that an interest obtained through an agreement supported by consideration is superior to that of a named beneficiary who has given no consideration holding that consideration should have been given to the ways in which a particular placement would distance a native american youth from his family and tribe and noting more generally that district courts should give due consideration to the unique concerns and needs of native american youth holding requirement of additional consideration and presumption of atwill employment are both rules of construction rather than substance and implied contract needs no additional consideration where intention of parties is clear holding that jury trial in civil cases is not so fundamental to the american system of justice as to be required of state courts by due process holding that courts should give due consideration to the premise that equality of distribution among creditors is a central policy of the bankruptcy code