between the Indian Nations and the United States is that of nations. Ex parte Crow Dog, U.S. courts do not have criminal jurisdiction in cases where one Native American murders another on reservation lands. The Supreme Court also ruled that tribes held exclusive jurisdiction over their own internal affairs, including murder cases. The U.S. Congress responded with the Major Crimes Act, by which Congress has exercised since absolute (plenary) power over tribal jurisdiction by excluding certain crimes from that jurisdiction. This case was the beginning of the plenary power legal doctrine that has been used in Indian case law to limit tribal sovereignty. Elk v. Wilkins, An Indian cannot make himself a citizen of the United States without the consent and the co-operation of the United States Federal government. United States v. Kagama, Congress has plenary power over all Native American tribes within its borders. Talton v. Mayes, Constitutional protections including the provisions of the Bill of Rights do not apply to the actions of American Indian tribal governments. Lone Wolf v. Hitchcock, Congress may use its plenary power to unilaterally break treaty obligations between the United States and Native American tribes. Williams v. Lee, State courts do not have jurisdiction on Indian reservations without the authorization of Congress. Menominee Tribe v. United States, Native American treaty rights are not repealed without a clear and unequivocal statement to that effect from Congress. Oneida Indian Nation of New York v. County of Oneida, There is federal subject-matter jurisdiction for possessory land claims brought by Indian tribes based upon aboriginal title, the Nonintercourse Act, and Indian treaties. Bryan v. Itasca County, A state does not have the right to assess a tax on the property of a Native American (Indian) living on tribal land absent a specific Congressional grant of authority to do so. Oliphant v. Suquamish Indian Tribe, Indian tribal courts do not have inherent criminal jurisdiction to try and to punish non-Indians, and hence may not assume such jurisdiction unless specifically authorized to do so by Congress. United States v. Wheeler, The Fifth Amendment's Double Jeopardy Clause does not prevent prosecution by both an Indian tribe and the federal government of the United States. Santa Clara Pueblo v. Martinez, Title I of the Indian Civil Rights Act does not expressly or implicitly create a cause of action for declaratory and injunctive relief in the federal courts. Solem v. Bartlett, The