It could find that a claim was valid and award compensation.

It could not order land returned.

This limitation would prove significant when the Black Hills claim reached the Commission.

The Commission heard the Black Hills claim over many years, involving extensive historical research, expert testimony, and legal argument.

The fundamental dispute was about what had actually happened in 1877 — whether the act of that year was a valid exercise of congressional power or a seizure that violated the treaty and the Constitution.

The Commission ultimately found the latter.