By incorporating into the United States, the Court found that Tribes "necessarily up their power to try non-Indian citizens of the United States except in a manner acceptable to Congress". Arguing that non-Indian citizens should not be subjected to another sovereign's "customs and procedure", the Court analogizes to "Crow Dog". In "Crow Dog", which was decided before the Major Crimes Act, the Court found exclusive Tribal jurisdiction over Tribe-members because it would be unfair to subject Tribe-members to an "unknown code" imposed by people of a different "race [and tradition" from their own.