Paul v. United States, 20 Cl.Ct. 236 (1990), was a Congressional reference case brought before the United States Claims Court as a result of Senate Resolution 187 of the 100th Congress' 1st Session in 1988, which referred the proposed private bill, S. 966 to the court for a report on whether Frederick Paul's claim was a legal, equitable, or gratuitous claim and what amount was legally or equitably due him by the United States. Paul claimed he was due additional money from the government for his work with the native Inuit of Alaska that led to the passage of the Alaska Native Claims Settlement Act in 1971 and the creation of the modern borough system of local government in Alaska. The hearing officer held that while Paul did not have a legal or equitable claim to the money, if Congress did grant him the money, it would be as payment of an equitable claim and not as a gratuity. The review panel to the case agreed that there was no legal or equitable claim, but held that any payment would be a gratuity. Subsequently, Congress failed to act on the proposed bill before Mr. Paul's death in 1994. Background In 1966, natives from the Alaskan Arctic Slope villages of Kaktovik, Nooiksat, Barrow, Wainwright, Point Lay, Point Hope, Anaktuvuk Pass, Meade River, Wood's Camp and Colville joined together to form the Arctic Slope Native Association (ASNA) to represent their land interests to the Bureau of Indian Affairs (BIA). While Frederick Paul was not the organization's initial legal representative, he was appointed as a representative shortly after and sought to negotiate a contract with the BIA for his services on behalf of the natives. However, the Bureau rejected his proposed contract as it was not sure if the ASNA was an actual organization and because it disagreed with Paul receiving a percentage of any eventual recovery. Despite the BIA's rejection, Paul submitted a substantially similar contract to the ASNA, which signed it. The Bureau notified him that the contract was not valid and subsequently he re-executed the same contract with seven of the eight villages comprising the ASNA. The Bureau again denied the contracts citing that they were not the same form as the standard contract and that the rate should be three times the usual hourly rate and not a percentage of the eventual recovery. During this time, Paul made substantial