against M'Intosh in the United States District Court for the District of Illinois, contending that their chain of title was superior by virtue of Johnson's purchases. The District Court dismissed the claim on the grounds that the Piankeshaw were not able to convey the land. Opinion Marshall, writing for a unanimous court, affirmed the dismissal. Marshall begins with a lengthy discussion of history of the European colonization of the Americas and the legal foundations of the American Colonies. In particular, Marshall focuses on the manner in which each European power took land from the indigenous occupants. Synthesizing the law of colonizing powers, Marshall traces the outlines of the "discovery doctrine"—namely, that a European power gains radical title (also known as sovereignty) to the land it discovers. As a corollary, the "discovering" power gains the exclusive right to extinguish the "right of occupancy" of the Indigenous occupants, which otherwise survived the assumption of sovereignty. Marshall further opined that when it declared independence from the Crown, the United States government inherited the right of preemption over Native American lands. The legal result is that the only Native American conveyances of land which can create valid title are sales of land to the federal government. Legacy Law and economics At least one commentator has noted that Johnson, by holding that only the federal government could purchase Native American lands, created a system of monopsony, which avoided bidding competition between settlers and thus enabled the acquisition of Native American lands at the lowest possible cost. Role in law school curriculum Prof. Stuart Banner at UCLA School of Law, writes of the case: Johnsons continuing prominence is reinforced every year in law schools, where it is the very first case most beginning students read in their required course in Property. The bestselling property casebook calls Johnson 'the genesis of our subject' because it lays 'the foundations of landownership in the United States.' Given current understandings surrounding Indigenous law, and the role of Native Americans in America, the outcome of the case has come to be viewed with disapproval in law school. Johnson has joined Dred Scott v. Sandford and a few others to form a small canon (or maybe an anti-canon) of famous cases law students are taught to criticize. The leading casebook describes the philosophy underlying Johnson as "discomforting" and quotes with approval the recent view of a law professor that Marshall's opinion "was