for Itasca County's interpretation. Brennan also noted that the several tribal termination acts which were considered at the same time specifically discussed the taxation of Indians, while Public Law 280 was silent. Brennan then noted that the principles of statutory construction as regards to Indians were very specific. Any differences in possible interpretation must be resolved in favor of the tribe or the Indian. Since Minnesota's interpretation did not meet any of these tests regarding either the consent of Congress to tax or of statutory construction, Brennan stated that the Supreme Court would not follow the state's reasoning, and reversed the lower court's decision. Subsequent developments When the decision was announced, it was reported as a substantial victory for Indians by both the local and national press. Bryan is a landmark case on the taxation of Indians and tribal sovereignty, having been cited over 380 times as of July 2010. The case has had a significant impact on Indian gaming with its broad holding that Public Law 280 did not confer "general state civil regulatory control over Indian reservations." This ruling in a challenge to a tax bill of under $200 had the effect of enabling Indian tribes nationwide to earn over $200 billion in gaming revenue as of 2007. The first cases influenced by Bryan involved bingo, which many states allowed, but regulated. The cases which were decided all cited Bryan in holding that the various states had no legal grounds to regulate games on tribal land. Many analysts point to the Bryan case as being the grounds upon which California v. Cabazon Band of Mission Indians was decided. The Supreme Court noted that California was not able to impose civil regulations against an Indian tribe on tribal land. In that case, the court noted that California not only allowed gaming, but promoted its own state lottery. Therefore, the prohibition against gaming was regulatory in nature, not criminal, notwithstanding the fact that the games were open to non-Indians as well as Indians. After the decision, Congress passed the Indian Gaming Regulatory Act to provide for a system of regulation of the Indian gaming industry. The case is often cited to support the concept which first "coalesced" in the 1968 case, Menominee Tribe of Indians v. United States, , that tribal rights would not be abrogated without an explicit intent of Congress to do so. It has been opined by