Freedmen Minor Freedmen Delaware Indians (those adopted by the Cherokee tribe were enrolled as a separate group within the Cherokee) More than 250,000 people applied for membership, and the Dawes Commission enrolled just over 100,000. Most were rejected because they were non-Natives who showed up demanding land, but could not prove any connection to an existing Native community, such as naming living relatives or speaking the Native language. Overrun with prospective claimants, the commission was overwhelmed, and had to institute guidelines: An act of Congress on April 26, 1906, closed the rolls on March 5, 1907. An additional 312 persons were enrolled under an act approved August 1, 1914. While some initially refused to be enumerated, almost all were later arrested and enrolled against their will; enrollment was not a matter of "choice." Refusing to be enumerated, and even fleeing, would mean warrants being issued for the person's arrest; they could then be treated brutally and imprisoned in the process of being enrolled by force. Still, due to understandable distrust of the government, there were those who tried to avoid ennumeration. Notable among those who resisted were Muscogee Chitto Harjo (Crazy Snake), and Cherokee Redbird Smith. But both Harjo and Smith were eventually coerced into enrolling. According to Cherokee professor Steve Russell, some Natives hiding in the Cookson Hills never did enroll, but some of them were later arrested and forcibly enrolled, while others were enrolled on their behalf by people in their communities. Additionally all individuals on the Census Roll of 1896 were enrolled without notification to the parties involved. The only real choice to avoid enumeration entirely meant completely leaving one's community and assimilating. Since that period, the tribes have relied on the Dawes Rolls as part of the membership qualification process, using them as records of citizens at a particular time, and requiring new members to document direct descent from a person or persons on these rolls. Courts have upheld this rule even when it has been proven that a brother or sister of an ancestor was listed on the rolls but not the direct ancestor himself/herself. Another issue on the Dawes Rolls are people termed "Five-Dollar Indians." Some white people bribed government officials in order to get land allotments, but this was not as widespread as some would believe. Gregory Smithers, associate professor of history at Virginia Commonwealth University stated, "These were opportunistic white men who