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The article evaluates the theory of the Yellowstone Zone of Death and its implications for criminal law.

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February 28, 2026

C.J. Box and the Yellowstone Zone of Death

Key Points

The article evaluates the theory of the Yellowstone Zone of Death and its implications for criminal law.
Summarizes the Yellowstone Zone of Death theory and its origin in a Georgetown Law Journal article.
Analyzes its representation in C.J. Box's novel Free Fire.
Discusses the reasons why the legal loophole remains unaddressed.
Examines public reactions and attention surrounding the theory.
Presents new counterarguments to the theory not previously addressed.
The Yellowstone Zone of Death theory highlights a significant legal vulnerability in Idaho.
C.J. Box’s novel brings attention to this loophole, increasing public interest.
Despite public focus, efforts to resolve the loophole remain ineffective.
New counterarguments arise in response to growing scrutiny of the theory.

Abstract

C.J. Box’s novel Free Fire incorporated the theory, first published in the Georgetown Law Journal article The Perfect Crime, that there is a 50-square-mile swath of Idaho where criminals might evade punishment because of an unfortunate oversight in the law. Part II of this Article summarizes this “Yellowstone Zone of Death” theory and examines its treatment in Free Fire. Part III discusses why the loophole still has not been closed. Part IV summarizes the public attention the theory has received. Last, Part V addresses some new counterarguments to the theory that arose out of this public attention, and that were not addressed in The Perfect Crime.

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