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Yellowstone ‘Zone Of Death’ Theory Circulates In Search For Missing Idaho Children

SALT LAKE CITY, Utah – A theory circulating on social media could shed light on why Tylee Ryan was last seen at Yellowstone National Park, and why some say a 50-square-mile portion on the Idaho side of the park is the perfect location to get away with murder.

Detectives said the last known sighting of Ryan, 17, was during a family day trip from Rexburg to Yellowstone National Park on Sept. 8, 2019.

According to detectives, phone records determine that Ryan visited the park along with her uncle Alex Cox, mother Lori Vallow, and younger brother JJ. Investigators have asked for the public’s help in tracking down the group’s whereabouts when they visited the park.

Yellowstone National Park is known for its wildlife and geothermal features, but a remote area known as the Zone of Death is drawing speculation on social media and the search for Ryan and JJ Vallow.

Zone Of Death

“The area in question is the 50-square-mile little rectangle in Idaho that is in Yellowstone Park,” said Brian Kalt, professor of law at Michigan State University Law School. “The only sort of development in the Idaho portion is the Bechler Ranger Station.”

Current law, according to Kalt, opens the door to the possibility of getting away with murder in this particular area.

“If a crime is committed there, then the jury has to be from the state — Idaho — and the district — District of Wyoming — where the crime was committed. So the jury would have to be from this little zone in the park, and nobody lives there,” Kalt said.

He explained that the Sixth Amendment of the Constitution requires that a federal criminal defendant have a jury from the state and district where the crime was committed.

According to Kalt, another component is that the federal government has exclusive jurisdiction over any crimes that occur in Yellowstone. Therefore, the state of Idaho can not prosecute a crime there.

That means if a crime was committed against the children in this area, a suspect could walk by virtue of not having a jury, based on Kalt’s analysis.

“If someone committed a crime there and had a right to a jury trial, if it was a major crime, then there’s no way to prosecute them successfully,” he said. “That’s the theory.”

Kalt said it would also be difficult to transfer the case to another jurisdiction because the defendant would have to waive their Sixth Amendment right.

There are also other charges that a defendant could be held accountable for in another jurisdiction, such as conspiracy or premeditation.

“So even if something happened in the Idaho portion of the park, they might still get them for something else,” Kalt said. “Then the theory might not work, or the courts would reject it and she would get convicted anyway.”

Kalt first wrote about the jurisdictional black hole in 2004. He said he delayed publication for about a year because he wanted to get it fixed. However, he said Congress didn’t take action.

Getting the theory to stand in court is another matter, but he said there is a chance – especially in an appeal process with a higher court.

“(A defendant) could use that as a defense and it might work,” Kalt said. “It probably wouldn’t work in a trial court, but on appeal, I think there is a good chance that it would.”

Vallow’s Trip To Yellowstone

It’s currently unclear what portion of the park Vallow’s group visited in September.

In a statement to KSL, FBI spokesperson Sandra Barker for the Salt Lake Bureau could only confirm the pictures released by the FBI of the group at Yellowstone on Sept. 8 “came from electronic media seized during the investigation.”

She declined to say where in the park they were taken.

According to court documents, a picture of Ryan at the park’s entrance was recovered from the National Park Service, which is on the Wyoming side. The location is several miles from the Bechler Ranger station, which leads to the Zone of Death.

“To me it looked like they were not in the Idaho portion,” Kalt said. “It looked like they were near a geyser. There are not really the thermal features in the Idaho portion that you see in the rest of the park.”

Kalt added that the pictures do not look like they came from the Zone of Death.

However, a closer look revealed that the Zone of Death is closer to Rexburg than the park’s entrance. According to court documents, the group traveled from Rexburg to the park during a “day trip.”

“It’s a little bit closer, maybe 10 – 15 minutes driving, because it’s a bunch of backroads,” Kalt said. “You would really have to know where you were going to get there.”

Photos of the Children

The FBI in March asked the public to submit any photos or videos they may have taken at Yellowstone on Sept. 8, 2019. As of May 1, the bureau confirmed it has received about 200 submissions to its tip page.

Authorities said those tips will hopefully lead to answers of what happened to Ryan during the trip.

“It’s a huge park, and there’s lots of dangerous things there,” Kalt said.

JJ Vallow was spotted for 16 more days after the day trip to Yellowstone. He was last seen at school on Sept. 23, 2019.

More information on the “Zone of Death” from Brian C. Kalt. 

The Perfect Crime

Tabloid Constitutionalism: How a Bill Doesn’t Become a Law

If you have any information relating to the disappearance of JJ Vallow and Tylee Ryan, contact the Rexburg Police Department at 208-259-3000 or go to

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