France, the original discoverers. Marshall noted: Marshall noted the 1455 papal bull approved Portugal's claims to lands discovered along the coast of West Africa, and the 1493 had ratified Spain's right to conquer newly found lands. Marshall stated, however, "Spain did not rest her title solely on the grant of the Pope. Her discussions respecting boundary, with France, with Great Britain, and with the United States, all show that she placed it on the rights given by discovery. Portugal sustained her claim to the by the same title." Marshall pointed to the exploration charters given to the explorer John Cabot as proof that other nations had accepted the doctrine. Legal critique Allison Dussias states that the Piankeshaw were not party to the litigation and therefore, "no Indian voices were heard in a case which had, and continues to have, profound effects on Indian property rights." McNeil states that the authority for the doctrine of discovery, as formulated by Marshall, was "flimsy". Furthermore, Indigenous nations in North America were factually independent and sovereign prior to the arrival of Europeans and therefore the European powers should not have been able to acquire territorial sovereignty by discovery and settlement, but only by conquest or cession. Pagden states that Marshall did not sufficiently consider Francisco de Vitoria's critique of the claim that discovery gave a right to possession of inhabited lands. Vitoria, however, stated that the Spanish could claim possession of the Americas by conquest if indigenous populations violated principles of natural law. Blake Watson states that Marshall overlooked evidence showing that the Dutch and some English settlers acknowledged the right of Indians to their land and favored purchase as a means of acquiring title. Watson and others, such as Robert A. Williams Jr., state that Marshall misinterpreted the "discovery doctrine" as giving exclusive right to lands discovered, rather than the exclusive right to treaty with the inhabitants who owned that land. Other United States cases In Cherokee Nation v. Georgia (1831), the US Supreme Court found that the Cherokee Nation was a "domestic dependent nation" with no standing to take action against the state of Georgia. In Worcester v Georgia (1832), Marshall re-interpreted the doctrine of discovery. He stated that discovery did not give the discovering nation title to land, but only "the sole right of acquiring the soil and making settlements on it." This was a right of preemption which only applied