 Lands south of the Arkansas River had been deeded to the Choctaw in 1820s, but white settlement and Cherokee relocation continued apace into the 1820s, spurring conflicts over the prime river-bottom lands.In 1822, the Council Oaks Treaty meeting was held under two large oak trees, reestablishing Cherokee title of north of the Arkansas River previously granted in 1817 in exchange for removing north of the river.The Cherokee that remained south of the river became known as the "Black Dutch", and largely assimilated.