It did not.

The case grew out of a much older struggle over Ponca land and the expanding authority of the United States on the northern Plains.

The Ponca were a distinct nation with their own homeland, political life, families, and relationship to the land long before Nebraska became a state.

Through the nineteenth century, however, treaties with the United States progressively constrained the territory available to them.

As settler expansion accelerated, treaty lines that looked fixed on paper were repeatedly subjected to new negotiations, new pressures, and new federal priorities.

An 1858 treaty reduced the Ponca land base, and an 1865 treaty established a reservation along the Niobrara River in northeastern Nebraska.