context: Based on this language in the Indian General Allotment Act, courts have determined that "the protections of the Nonin-tercourse Act do not apply to land which has been rendered freely alienable by Congress, held by private parties, and subsequently acquired by an Indian tribe."
citation_a.signal: see also
citation_a.identifier: 5 F.3d 1355, 1359
citation_a.parenthetical: holding that "once Congress removes restraints on alienation of [Indian] land, the protections of the Nonintercourse Act no longer apply"
citation_a.sentence: Cass Cnty., 643 N.W.2d at 696; see also Lummi Indian Tribe v. Whatcom Cnty., Wash., 5 F.3d 1355, 1359 (9th Cir.1993) (holding that “once Congress removes restraints on alienation of [Indian] land, the protections of the Nonintercourse Act no longer apply”); Mashpee Tribe v. Watt, 542 F.Supp. 797, 803 (D.Mass.1982); Bay Mills Indian Cmty. v. State, 244 Mich.App. 739, 626 N.W.2d 169, 174 (2001); Anderson & Middleton Lumber Co. v. Quinault Indian Nation, 130 Wash.2d 862, 929 P.2d 379, 387 (1996); cf. City of Sher- rill, N.Y. v. Oneida Indian Nation of N.Y., 544 U.S. 197, 202-03, 125 S.Ct. 1478, 161 L.Ed.2d 386 (2005) (holding that the Oneida tribe could not “unilaterally revive its ancient sovereignty” over land “through open-market purchases from current titleholders” even though the land had previously been reservation land).
citation_b.signal: cf.
citation_b.identifier: 544 U.S. 197, 202-03
citation_b.parenthetical: holding that the Oneida tribe could not "unilaterally revive its ancient sovereignty" over land "through open-market purchases from current titleholders" even though the land had previously been reservation land
citation_b.sentence: Cass Cnty., 643 N.W.2d at 696; see also Lummi Indian Tribe v. Whatcom Cnty., Wash., 5 F.3d 1355, 1359 (9th Cir.1993) (holding that “once Congress removes restraints on alienation of [Indian] land, the protections of the Nonintercourse Act no longer apply”); Mashpee Tribe v. Watt, 542 F.Supp. 797, 803 (D.Mass.1982); Bay Mills Indian Cmty. v. State, 244 Mich.App. 739, 626 N.W.2d 169, 174 (2001); Anderson & Middleton Lumber Co. v. Quinault Indian Nation, 130 Wash.2d 862, 929 P.2d 379, 387 (1996); cf. City of Sher- rill, N.Y. v. Oneida Indian Nation of N.Y., 544 U.S. 197, 202-03, 125 S.Ct. 1478, 161 L.Ed.2d 386 (2005) (holding that the Oneida tribe could not “unilaterally revive its ancient sovereignty” over land “through open-market purchases from current titleholders” even though the land had previously been reservation land).