In 1879, part-Cherokee Elias C. Boudinot argued that these Unassigned Lands be open for settlement because the title to these lands belonged to the United States and "whatever may have been the desire or intention of the United States Government in 1866 to locate Indians and negroes upon these lands, it is certain that no such desire or intention exists in 1879. The Negro since that date, has become a citizen of the United States, and Congress has recently enacted laws which practically forbid the removal of any more Indians into the Territory".