members of the Alberta Métis Settlements. The MSA test excludes those people who are Status Indians (that is, a member of a First Nation), an exclusion which was upheld by the Supreme Court in Alberta v. Cunningham (2011). The number of people self-identifying as Métis has risen sharply since the late 20th century: between 1996 and 2006, the population of Canadians who self-identify as Métis nearly doubled, to approximately 390,000. From 2006 to 2016, according to census results from Statistics Canada, those numbers rose by 125% in Nova Scotia, and 150% in Quebec. Also in that time, "Dozens" of new "Metis" organizations appeared, none of whom could demonstrate any ties to continually-existing Métis communities. Until R v. Powley (2003), there was no legal definition of Métis other than the legal requirements found in the Métis Settlements Act of 1990. The Powley case involved a claim by Steven Powley and his son Rodney, two members of the Sault Ste. Marie, Ontario Métis community who were asserting Métis hunting rights. The Supreme Court of Canada outlined three broad factors to identify Métis who have Hunting Rights as Aboriginal peoples: All three factors must be present for an individual to qualify under the SCC legal definition of Métis. In addition, the court stated that Questions remain as to whether Métis have treaty rights; this is an explosive issue in the Canadian Aboriginal community today. It has been stated that "only First Nations could legitimately sign treaties with the government so, by definition, Métis have no Treaty rights." One treaty names Métis in the title: the Halfbreed (Métis in the French version) Adhesion to Treaty 3. Another, the Robinson Superior Treaty of 1850, listed 84 persons classified as "half-breeds" in the Treaty, so included them and their descendants. Hundreds, if not thousands, of Métis were initially included in a number of other treaties, and then excluded under later amendments to the Indian Act. Definitions used by Métis representative organizations Two main advocacy groups claim to speak for the Métis in Canada: the Congress of Aboriginal Peoples (CAP) and the Métis National Council (MNC). Each uses different approaches to define Métis individuals. The CAP, which has nine regional affiliates, represents all Indigenous peoples in Canada who are living off-reserve, including Métis and non-Status Indians. It does not provide a definition of "Métis", but instead leaves each affiliate determine its own membership criteria. Due to the