In his 1935 Memorandum to John Collier, Commissioner of Indian Affairs, the Assistant Solicitor, Felix S. Cohen, discussed the rights of a group of non-tribal Indians under the Indian Reorganization Act. This Act defined a person as Indian based on three criteria, tribal membership, ancestral descent, or blood quantum. (Cohen said of the group now known as the Lumbee Indians, recognized by the state of North Carolina: "this group is not a federally recognized Indian tribe. Neither are the members of this group residents of an Indian reservation.")