efforts on behalf of the ASNA to ensure the natives received money for the land of the Arctic Slope that was being sold to various oil concerns, culminating in the passage of the Alaska Native Claims Settlement Act of 1971 (ANCSA), which provided over forty-six million dollars and several million acres of land to the natives in compensation for their land claims. It also provided for the attorneys who had assisted the natives in preparing their claims to receive up to 1.9 million dollars if they filed a request for payment within one year of the law's passage. Paul claimed he was due over 10 million dollars, later reducing the claim to 5.9 million and then having a court find the amount at 3.6 million. However, during the distribution of the 1.9 million dollars, Paul was only paid two-hundred seventy-five thousand dollars and continued to seek further remuneration, filing a suit in 1974 in Alaska against ANSA and the cities he had contracted with. This resulted in a judgment for twenty-thousand dollars to Paul. Paul then filed a claim in the Western District of Washington for the same claim in 1976, only to have the court dismiss it in light of the statute of limitations. In 1977 Paul sued the United States in the Court of Claims arguing that the ANCSA had unconstitutionally infringed on his contract. That suit was dismissed by the court for failing to state a claim that the court could render a judgment under. Also in 1977, Paul sued the United States, the villages and several associations in Alaska federal court for his own fees and the fees of other attorneys. The court dismissed this claim citing that they were not contracts made under the ANCSA or claims that could be paid otherwise. Paul re-filed suit against the United States, ASNA, and eight villages for fees in the Western District of Washington during the same year, only to have the court suspend the case in light of the other pending litigation. Congressional reference Paul appealed to his congressman and his senators for the passage of a reference resolution to empower the Claims Court to hear his dispute. Despite the introduction of resolutions in the 98th (Senate Resolution 432 and House Resolution 571) and 99th (S. Res. 78 and H. Res. 61) Congresses, no action was taken. Finally, in 1998, Senate Resolution 187 was approved, which directed