Citation to "Johnson" has been a staple of federal and state cases related to Native American land title for 200 years. Like "Johnson", nearly all of those cases involve land disputes between two non-Native parties, typically one with a chain of title tracing to a federal or state government and the other with a chain of title predating US sovereignty. A similar trend can be seen in the early case law of Australia, Canada, and New Zealand. The first land dispute involving an indigenous party to reach to the Supreme Court was "Cherokee Nation v. Georgia" (1831).