In 1985 the US Supreme Court ruled in "US v. Dann," the legal case brought by Western Shoshone sisters Carrie and Mary Dann challenging federal agency efforts to regulate their grazing of livestock on traditional lands, that the appropriation of funds by Congress and the acceptance of this action by the Secretary of the Interior constitutes "payment" and puts into effect Section 70 U of the Indian Claims Commission (ICC) Act, forever barring further claims. It ruled that Western Shoshone title is 'presumed to be extinguished.'