Judge Advocate General of the Army, David G. Swaim, found the prosecution's case against Whittaker to be illegal and based on racial bias. The administration faced a different challenge in the West, where the LDS Church was under government pressure to stop the practice of polygamy in Utah Territory. Garfield had believed polygamy was criminal behavior and was morally detrimental to family values, and Arthur's views were, for once, in line with his predecessor's. In 1882, he signed the Edmunds Act into law; the legislation made polygamy a federal crime, barring polygamists both from public office and the right to vote. Native American policy The Arthur administration was challenged by changing relations with western Native American tribes. The American Indian Wars were winding down, and public sentiment was shifting toward more favorable treatment of Native Americans. Arthur urged Congress to increase funding for Native American education, which it did in 1884, although not to the extent he wished. He also favored a move to the allotment system, under which individual Native Americans, rather than tribes, would own land. Arthur was unable to convince Congress to adopt the idea during his administration but, in 1887, the Dawes Act changed the law to favor such a system. The allotment system was favored by liberal reformers at the time, but eventually proved detrimental to Native Americans as most of their land was resold at low prices to white speculators. During Arthur's presidency, settlers and cattle ranchers continued to encroach on Native American territory. Arthur initially resisted their efforts, but after Secretary of the Interior Henry M. Teller, an opponent of allotment, assured him that the lands were not protected, Arthur opened up the Crow Creek Reservation in the Dakota Territory to settlers by executive order in 1885. Arthur's successor, Grover Cleveland, finding that title belonged to the Native Americans, revoked Arthur's order a few months later. Health, travel, and 1884 election Shortly after becoming president, Arthur was diagnosed with Bright's disease, a kidney ailment now referred to as nephritis. He attempted to keep his condition private, but by 1883 rumors of his illness began to circulate; he had become thinner and more aged in appearance, and struggled to keep the pace of the presidency. To rejuvenate his health outside the confines of Washington, Arthur and some political friends traveled to Florida in April 1883. The vacation had the opposite effect, and Arthur suffered