Under the Medicine Lodge Treaty, the tribes were assigned reservations of diminished size compared to territories defined in an 1865 treaty. The treaty tribes never ratified the treaty by vote of adult males, as it required. In addition, by changing allotment policy under the Dawes Act and authorizing sales under the Agreement with the Cheyenne and Arapaho (1890) and the Agreement with the Comanche, Kiowa and Apache (1892) signed with the Cherokee Commission, the Congress effectively further reduced their reservation territory. The Kiowa chief Lone Wolf filed suit against the government for fraud on behalf of the tribes in "Lone Wolf v. Hitchcock". In 1903 the U.S. Supreme Court ruled against the tribes, determining that the Congress had "plenary power" and the political right to make such decisions. In the aftermath of that case, Congress acted unilaterally on land decisions related to other reservations as well.