favor, declaring that the Cherokee Nation was subject only to federal law and that the Supremacy Clause barred legislative interference by the state of Georgia. Chief Justice Marshall argued, "The Cherokee nation, then, is a distinct community occupying its own territory in which the laws of Georgia can have no force. The whole intercourse between the United States and this Nation, is, by our constitution and laws, vested in the government of the United States." The Court did not ask federal marshals to carry out the decision. Worcester thus imposed no obligations on Jackson; there was nothing for him to enforce, although Jackson's' political enemies conspired to find evidence, to be used in the forthcoming political election, to claim that he would refuse to enforce the Worcester decision. He feared that enforcement would lead to open warfare between federal troops and the Georgia militia, which would compound the ongoing crisis in South Carolina and lead to a broader civil war. Instead, he vigorously negotiated a land exchange treaty with the Cherokee. After this, Jackson's political opponents Henry Clay and John Quincy Adams, who supported the Worcester decision, became outraged by Jackson's alleged refusal to uphold Cherokee claims against the state of Georgia. Author and political activist Ralph Waldo Emerson wrote an account of Cherokee assimilation into the American culture, declaring his support of the Worcester decision. Nevertheless, the actions of the Jackson administration were not isolated because state and federal officials had violated treaties without consequence, often attributed to military exigency, as the members of individual Indian nations were not automatically United States citizens and were rarely given standing in any U.S. court. While citizenship tests existed for Indians living in newly annexed areas before and after forced relocation, individual U.S. states did not recognize the Indian nations' land claims, only individual title under State law, and distinguished between the rights of white and non-white citizens, who often had limited standing in court; and Indian removal was carried out under U.S. military jurisdiction, often by state militias. As a result, individual Indians who could prove U.S. citizenship were nevertheless displaced from newly annexed areas. Choctaw removal The Choctaw nation resided in large portions of what are now the U.S. states of Alabama, Mississippi, and Louisiana. After a series of treaties starting in 1801, the Choctaw nation was reduced to . The Treaty of Dancing Rabbit Creek ceded the remaining country