November 2008. It was the only contest on the ballot because CNMI elections traditionally occurred in odd-numbered years. Gregorio Sablan won the election and took office in January 2009. Native American treaty-right delegates The Cherokee and Choctaw Native American tribes have treaty rights to send delegates to Congress. The right to a non-voting delegate to Congress was promised to the Cherokee by the Treaty of Hopewell in 1785 (affirmed in 1835's Treaty of New Echota) and to the Choctaw under the Treaty of Dancing Rabbit Creek in 1830, "whenever Congress shall make provision for [a delegate]". Congress has never provided for the appointment of delegates from Indian tribes. The Choctaw tribe has never appointed a delegate to Congress and the Cherokee had not until 2019. However, the Choctaw did send a non-congressional delegate to Washington for most of the 19th century as an ambassador to represent them before the U.S. government, the most noteworthy being Peter Pitchlynn. In addition, the first treaty signed between the United States and a Native American nation, the Treaty of Fort Pitt (1778) with the Lenape ("Delaware Nation"), encouraged them to form a state that would have representation in Congress; however, it is unclear if the treaty would allow a delegate without the formation of a U.S. state. In 2022, Deborah Dotson, president of Delaware Nation, expressed an opinion that their treaty right was "stronger" than the Cherokees' and voiced frustration about their treaty promises being ignored. A similar situation actively exists at the state legislature level with the Maine House of Representatives maintaining seats for three non-voting delegates representing the Penobscot (since 1823), the Passamaquoddy (since 1842), and the Maliseet (since 2012). The rights of the tribal delegates has fluctuated over time but appears to have been born from a practice in Massachusetts General Court (Maine was a part of Massachusetts until 1820). Unlike the situation at the federal level, Maine's state-level tribal delegates are established by state law rather than treaties. As of 2015, only the Passamaquoddy seat is filled; the other two Nations have chosen to currently not fill their seats in protest over issues of tribal sovereignty and rights. The Wisconsin Legislature, the Legislative Assembly of New Brunswick in Canada, and the New Zealand Parliament were allegedly reviewing Maine's indigenous delegate policy for their own adoption (though New Zealand had already established Māori electorates since 1867). There remain, however, untested questions