State v. Elliott, 616 A.2d 210 (Vt. 1992), is a decision of the Vermont Supreme Court holding that all aboriginal title in Vermont was extinguished "by the increasing weight of history." The Vermont Supreme Court has clarified that its holding in Elliott applies to the entire state. Background In 1987, the land claim became an issue in the Abenaki chief election between Homer St. Francis and Lester Lampman. Lampman advocated that the tribe take a more aggressive stance in pushing its claim to "all of Vermont as well as parts of New Hampshire, Massachusetts and Maine." St. Francis won the election. On October 18, 1987, St. Francis organized a "fish-in" with 35 other tribal members on the Missisquoi River, conducted without licenses from the state. Just prior to the district court's decision, Chief St. Francis withdrew the tribe's petition for federal recognition, saying: "We don't need a Government we don't recognize to tell us we exist." Prior history The case arose in the aftermath two Vermont District Court decisions. State v. Saint Francis (1989) In State v. Saint Francis, on August 14, 1989, Judge Joseph J. Wolchik of the Vermont District Court in Franklin County, in a 96-page decision, held that the Abenaki were a tribe, retained aboriginal rights to hunt and fish, and therefore did not need to acquire fishing licenses from the state. Judge Wolchik held that the Abenaki's aboriginal area consisted of 500,000 acres in northwestern Vermont: Grand Isle County, most of Franklin County, and some of Chittenden and Orleans counties. Wolchik dismissed the charges against all but six of the defendants; he held that the remaining six were not tribal members. In the aftermath of the decision, Chief St. Francis vowed to file a land claim "as soon as possible." By then, St. Francis estimated the tribe's claim area as "all of Vermont, all of New Hampshire, and parts of northern Massachusetts, western Maine, upstate New York and southern Quebec." By September 12, 1990, several title insurance companies in Vermont attempted to amend their standard policy contracts (an action that requires approval from the state banking department) to exclude a potential Abenaki claim from coverage. State v. Bellevue (1990) In State v. Bellevue, on August 13, 1990, in another fishing rights case, Judge Edward Cashman of the Vermont District Court in Franklin County held that the Abenaki were not exempt from state criminal jurisdiction. Judge Cashman,