Johnson v. M'Intosh, 21 U.S. (7 Wheat.) 543 (1823), is a landmark decision of the U.S. Supreme Court that held that private citizens could not purchase lands from Native Americans. As the facts were recited by Chief Justice John Marshall, the successor in interest to a private purchase from the Piankeshaw attempted to maintain an action of ejectment against the holder of a federal land patent. The case is one of the most influential and well-known decisions of the Marshall Court, a fixture of the first-year curriculum in nearly all U.S. law schools. Marshall's opinion lays down the foundations of the doctrine of aboriginal title in the United States, and the related doctrine of discovery. However, the vast majority of the opinion is dicta; as valid title is a basic element of the cause of action for ejectment, the holding does not extend to the validity of M'Intosh's title, much less the property rights of the Piankeshaw. Thus, all that the opinion holds with respect to aboriginal title is that it is inalienable, a principle that remains well-established law in nearly all common law jurisdictions. Citation to Johnson has been a staple of federal and state cases related to Native American land title for 200 years. Like Johnson, nearly all of those cases involve land disputes between two non-Native parties, typically one with a chain of title tracing to a federal or state government and the other with a chain of title predating US sovereignty. A similar trend can be seen in the early case law of Australia, Canada, and New Zealand. The first land dispute involving an indigenous party to reach to the Supreme Court was Cherokee Nation v. Georgia (1831). The ruling essentially enforces the 1763 Royal Proclamation of King George III. Background Thomas Johnson, one of the first Supreme Court justices, bought land from Piankeshaw Native American tribes in 1773 and 1775. The plaintiffs were lessees of Thomas Johnson's descendants, who had inherited the land. The defendant, William M'Intosh (pronounced "McIntosh"), subsequently obtained a land patent, according to the facts as Marshall accepted them, to this same land from the United States. In fact, the two parcels did not overlap at all. Further, there is evidence that the parties were aware the tracts did not overlap and purposely misrepresented the facts to the court to obtain a ruling. Prior history The plaintiffs brought an action for ejectment