No Sticks in My Bundle: Rethinking the Indian Land Tenure Problem

In 1996, Eloise Cobell famously filed a class action against the Secretary of Interior claiming the agency had violated its federal trust responsibility to Native American citizens by failing to account for billions of dollars in Indian trust assets, including income from individual trust lands. The federal courts generally agreed that the government had breached its trust responsibility, and the parties settled for $3.4 billion. From these settlement funds, $1.9 billion is allocated to purchasing small fractional interests from willing Indian sellers in order to reduce fractionation, which is seen as exacerbating the Department of Interior's accounting challenges. See