Tribal lands and resources, then subsequently gave the rights to this property to non-Indian settlers. (4) Under the General Allotment Act of 1887, Tribal members were forced to surrender their previously undivided interest in Tribally owned trust estate for individually assigned land interests creating permanently divided land allotments on Tribal lands, and further coercing Native Americans into assimilation and dependency on the Federal Government, thus depriving them of their traditional economies. (5) Congress has acknowledged that this Reservation Era policy is widely known as failed Federal policy that established individual non-Indian land holdings on reservations resulting in checkerboarded Tribal lands that cause complex jurisdictional and legal complications today. (6) In response to these failed, paternalistic Federal assimilation policies, forced acquisition of indigenous lands, and genocide of Native Americans, the United States has recognized the unique legal relationship and trust responsibility it has with American Indians, Alaska Natives, and Native Hawaiians to promote their self-determination and sovereignty in furtherance of its treaty obligations and longstanding government-to-government relationship. (7) Congressional authority to manage this unique government-to-government relationship with Native nations and Indian affairs generally is recognized as plenary