On September 17, 1999, the Supreme Court of Canada upheld the treaty rights of Miꞌkmaw Donald Marshall Jr. its landmark "R v Marshall" ruling, which "affirmed a treaty right to hunt, fish and gather in pursuit of a 'moderate livelihood'." The Supreme Court also cited Section 35 of the 1982 Constitution Act in their 1999 ruling that resulted in Mi'kmaq, Maliseet, and Peskotomuhkati people the "right to hunt, fish and gather in pursuit of a 'moderate livelihood' from the resources of the land and waters." The legal precedent had previously been established in the Treaty of 1752, one in a series of treaties known as the Peace and Friendship Treaties, but was not being respected prior to "R v Marshall". This resulted in the 1993 charges laid against Marshall Jr. for "fishing eels out of season, fishing without a licence, and fishing with an illegal net". In the 2018 publication, "Truth and conviction: Donald Marshall Jr. and the Mi'kmaw quest for justice", Marshall was quoted as saying, "I don’t need a licence. I have the 1752 Treaty." The 1989 Royal Commission on the Donald Marshall, Jr. Prosecution resulted in a compensation to Marshall of a lifetime pension of $1.5 million. Marshall used the financial compensation to finance the lengthy and costly Supreme Court case. When Marshall won, 34 Mi'kmaw and Maliseet First Nations bands were affected in the provinces of New Brunswick, Prince Edward Island, Nova Scotia, and the Gaspé region of Quebec. The West Nova Fishermen's Coalition submitted an appeal asking for the Marshall decision to be set aside. In November 17, 1999, released a new ruling —Marshall 2—to clarify that the DFO had the power to regulate the fishery for conservation purposes if it "consulted with the First Nation and could justify the regulations".