In 2009 under Carcieri v. Salazar, the US Supreme Court ruled that the government could not take land into trust for tribes that were recognized after the passage of the Indian Reorganization Act of 1934.
Congress in 2014 passed Public Law No: 113-179 (09/26/2014), a law to clarify that the Match-E-Be-Nash-She-Wish Band's land trust assigned to them in 2005 could not be challenged in court under the United States Supreme Court decision of Carcieri v. Salazar.[REF][REF][REF] .