Title: 
Headings: 

Content: As Vine Deloria, Jr., wrote in Of Utmost Good Faith, in federal Indian law the Supreme Court "skips along spinning off inconsistencies like a new sun exploding comets as it tips its way out of the dawn of creation." In 1978 alone, the Court went from almost completely subordinating indigenous sovereignty under federal law in Oliphant v. Suquamish, 435 U.S. 191, to an affirmation of it as a third kind of sovereignty in the United States  in United States v. Wheeler, 435 U.S. 313. The latter decision was a complete contradiction of the analysis in Kagama. In 1997, in Idaho v. Coeur d'Alene Tribe, No. 94-1474, the Supreme Court held that "Indian tribes ... should be accorded the same status as foreign sovereigns, against whom States enjoy Eleventh Amendment immunity." This was a startling contrast to the foundational federal Indian law decision in Cherokee Nation v. Georgia, 5 Pet. 1 (1831) that the Cherokee were not sovereign as a "foreign nation." The concept of sovereignty, however convoluted and contradictory, remains an important part of federal Indian law. Tribal councils established under the Indian Reorganization Act are regarded as vehicles of "tribal sovereignty"; they act  as governments and not just as corporations, though they are often limited by federal funding and authority.