Introduction Throughout American history, the federal government has failed to follow a consistent approach in determining the legal and political status of individual Native Americans and Indian tribes. Such policies (i.e., treaty-making and reservations, allotment, reorganization, termination, and, currently, self-determination) range from the treatment of Indian tribes as sovereign nations to the assimilation of individual Native Americans as U.S. citizens in the dominant white society. (1) Assimilation generally meant that Native Americans should adopt Euro-American clothing, language, religion, and an agricultural lifestyle before qualifying for citizenship. Even at that, most Native Americans could only expect second-class citizenship status when it came to exercising their constitutional rights and protections. Simply put, the legal status of individual Native Americans has often been unclear.