The authority was part of the 1934 Indian Reorganization Act, but the state argued that the process could not hold for tribes that achieved federal recognition after 1934. The US Supreme Court upheld the state based on language in the act. At issue is of land in Charlestown which the Narragansetts purchased in 1991. The Narragansetts requested the DOI to take it into trust on their behalf in order to remove it from state and local control, after trying to develop it for elderly housing under state regulations in 1998.