Native American "blood" (biological descent). Some of the Freedmen of the Cherokee Nation of Oklahoma used to be such members. Following the Civil War, the U.S. government's 1866 treaty with the defeated Cherokee, who had been Confederate allies, required them to free their slaves and to provide the freedmen with citizenship in the tribe. By recent referendum, the Cherokee Nation limited membership to only those people who could show descent from at least one Native American listed on the Dawes Rolls. This excluded nearly 2000 Cherokee Freedmen, who, with their ancestors, had been participating in the tribe for generations. Litigation on this matter continues. The Indian Arts and Crafts Act of 1990 may be the only recent federal Indian legislation that was, at all stages of legislative deliberation, supported by Indians. This law required that only Indians be allowed to market their handicrafts as "Indian made" and be sold at Indian crafts fairs. This was to halt the economic loss to Indians due to questionable and fraudulent claims of this sort, which was estimated between $400 and $800 million a year. In the Act, Indian was described as "any individual who is a member of an Indian tribe; or for the purpose of this section is certified as an Indian artisan by an Indian tribe." An Indian tribe was defined more broadly than just to tribes with federal recognition, but also to "any Indian group that has been formally recognized as an Indian tribe by a State legislature or by a State commission or similar organization legislatively vested with State tribal recognition authority." The broadness sought in part to protect the civil liberties of those who have Indian heritage and culture, but are not tribal members. However, the definition was not broad enough to avoid disallowing many artists whose Indian background was not in doubt, including well-known Cherokee painter, Bert Seabourn. The 1994 federal legislation, the American Indian Religious Freedom Act, gives another common definition, defining an Indian as one who belongs to an Indian tribe, which is a group that "is recognized as eligible for the special programs and services provided by the United States to Indians because of their status as Indians." The result of there being multiple legal definitions of Indian is that one may be eligible to receive educational grants, but not health benefits, one may be eligible to be chief of a tribe but not