American Revolution. Although part of the Wabash Confederacy, the Piankeshaw nation took no part in the Northwest Indian War that followed the American Revolution. However, Piankeshaw suffered retaliation from colonizers for attacks made by other native tribes. President George Washington issued a proclamation forbidding harm to the Piankeshaw. During the late 18th century, the Piankeshaw population began to decline. Many of the Piankeshaw simply left and joined other Miami tribes. After the Americans and French suffered setbacks in the Revolution, notably the disastrous LaBalme expedition, some Piankeshaw joined tribes aligned with the British. At that time, in the West, the British looked as if they would be the victors. Others left during the economic depression caused by a depreciated United States currency and stagnated fur trade (due to unrest in the Northwest Indian Wars). The Piankeshaw suffered especially when 1781 brought a severe Winter followed by a Summer drought. Despite overall good relations with the new United States, some Piankeshaw resented the new settlers encroaching on their territory. Vincennes residents attacked a nearby village in the 1786 Battle of the Embarras River. An exodus of Piankeshaw left the Vincennes area and moved to Terre Haute, where they joined the Wea, or moved to Kaskaskia, Illinois. They joined with other tribes in attacking American settlers later that year, but aborted the attack after French residents pleaded for peace. By 1818, the Piankeshaw Chief Chekommia signed a treaty selling rights to much of their land to the United States. Johnson v. M'Intosh The plaintiff Johnson had inherited land, which was originally purchased from the Piankeshaw tribes. The defendant McIntosh claimed the very same land, he had purchased it under a grant from the United States government. In 1775 members of the Piankeshaw tribe sold certain land in the Indiana Territory to Lord Dunmore. He was a royal governor of Virginia. In 1805 the Piankeshaw conveyed much of the same land to William Henry Harrison, Governor of the Indiana Territory, which made conflicting title claims. In reviewing whether the courts of the United States should recognize land titles obtained from Native Americans prior to American independence, the court decided that they should not. Chief Justice John Marshall had large real-estate holdings that would have been affected if the case were decided in favor of Johnson. Rather than abstaining from the case due to conflicting interest, the Chief Justice wrote the decision for a