legally be known as Creek Freedmen. (38) In 1970, Congress passed the Principal Chiefs Act requiring the Chickasaw, Choctaw, Cherokee, Seminole, and Creek Nations to obtain approval for their voting laws for selection of each nations Principal Chief. The Department of the Interior drafted a policy stating that it was not necessary that each of these groups has identical or similar regulations, but that 3 conditions are deemed fundamental to the democratic selection of a principal Tribal official. One of the three conditions stipulated by the Department was that voter qualifications of the Creeks must be broad enough to include the enrolled Creek Freedmen citizens. (39) On or about August 18, 1975, the Creek Nation, through its National Council, submitted to the Department of the Interior a draft constitution ( Draft Constitution ) that, among other things, contained express provisions that— (A) stripped individuals on the 1906 Creek Freedmen Rolls and their then-living lineal descendants of their Creek citizenship