Since the inception of the United States, there have been tensions between states and tribes about the extent to which state law applies on Indian reservations. In the 1830s, Chief Justice John Marshall issued a series of opinions recognizing tribal immunity from state law. He explained that tribes are pre-constitutional sovereign nations operating their own government and state law did not apply within reservation boundaries. However, later Supreme Court decisions and congressional acts eroded these protections, which made room for state law encroachment.
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