In his Cherokee Nation v. Georgia opinion, Chief Justice John Marshall stated that

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Chief Justice John Marshall described the relationship between Native American tribes and the United States government by stating that tribes were "domestic dependent nations" and their relationship to the U.S. resembled that of a "ward to its guardian." This established the tribes as sovereign entities but under the protection and authority of the U.S. government, without directly addressing citizenship, land rights, forced relocation, or the president's authority over Indian affairs in this specific context.

In His Cherokee Nation V