the spirit of the United States Constitution, article VI, section 2. (7) Serious questions remain regarding the rightful ownership of lands in several western and southwestern States. Certain public lands are the focus of such questions. (8) The Gadsden Purchase incorporated by reference the property protection provisions of the Treaty of Guadalupe Hidalgo. (9) Land claim commissions, appointed by Congress, have successfully examined disputed land possession claims. (10) The United States Government has recognized and upheld usufruct rights for other indigenous groups. (11) Between 1968 and 1981, the Forest Service recognized the uniqueness of the land tenure history in New Mexico and instituted what became known as the Northern New Mexico Policy for the Southwest Region to address the socioeconomic and cultural needs of the forest-dependent land grant-merced communities in New Mexico. (12) The United States General Accounting Office Report to Congressional Requesters, dated June 2004, numbered GAO–04–59, and entitled the Treaty of Guadalupe Hidalgo: Findings and Possible Options Regarding Longstanding Community Land Grant Claims in New Mexico , found the New Mexico land claims confirmation process was inefficient and caused hardships to claimants. Such report provided the following options for congressional consideration in addressing land grant-merced claims: (A) Consider establishing a commission or other body to reexamine specific Land Grant-Merced claims that were rejected or not confirmed for the full acreage claimed. (B) Consider transferring Federal land to communities that did not receive all of the acreage originally claimed for their community land grants. (C) Consider making financial payments to claimants’ heirs or other entities for the non-use of land originally claimed but not awarded. (13) The General Accounting Office also noted that Congress may disagree with the U.S. Supreme Court’s Sandoval 1897 decision and decide that it should be legislatively overruled , by addressing the affected land