on the state list, only the respective state legislature can legislate. For subjects on the concurrent list, both governments can make laws. However, to implement international treaties, Parliament can legislate on any subject and even override the general division of subject lists. United States See the article on the Bricker Amendment for the history of the relationship between treaty powers and Constitutional provisions. The U.S. Supreme Court ruled in the Head Money Cases (1884) that "treaties" do not have a privileged position over Acts of Congress and can be repealed or modified by legislative action just like any other regular law. The Court's decision in Reid v. Covert (1957) held that treaty provisions that conflict with the U.S. Constitution are null and void under U.S. law. Treaties and indigenous peoples Treaties formed an important part of European colonization and, in many parts of the world, Europeans attempted to legitimize their sovereignty by signing treaties with indigenous peoples. In most cases, these treaties were in extremely disadvantageous terms to the native people, who often did not comprehend the implications of what they were signing. In some rare cases, such as with Ethiopia and the Qing dynasty, local governments were able to use the treaties to at least mitigate the impact of European colonization. This involved learning the intricacies of European diplomatic customs and then using the treaties to prevent power from overstepping their agreement or by playing different powers against each other. In other cases, such as New Zealand with the Māori and Canada with its First Nations people, treaties allowed native peoples to maintain a minimum amount of autonomy. Such treaties between colonizers and indigenous peoples are an important part of political discourse in the late 20th and early 21st century, the treaties being discussed have international standing as has been stated in a treaty study by the UN. Australia In the case of Indigenous Australians, no treaty was ever entered into with the Indigenous peoples entitling the Europeans to land ownership, mostly adopting the doctrine of terra nullius (with the exception of South Australia). This concept was later overturned by Mabo v Queensland, which established the concept of native title in Australia well after colonization was already a fait accompli. Victoria On 10 December 2019, the Victorian First Peoples' Assembly met for the first time in the Upper House of the Parliament of Victoria in Melbourne. The main aim