In 2008, "Carcieri v Kempthorne" was argued before the U.S. Supreme Court; the Court ruled on it in 2009, with the decision called "Carcieri v. Salazar". In 1991, the Narragansett Indian tribe bought of land. They requested that the DOI take it into trust, which the agency did in 1998, thus exempting it from many state laws. The State was concerned that the tribe would open a casino or tax-free business on the land and sued to block the transfer. The state argued that the IRA did not apply because the Narragansett was not "now under federal jurisdiction" as of 1934, as distinguished from "federally recognized." In fact, the Narragansett had been placed under Rhode Island guardianship since 1709. In 1880, the tribe was illegally pressured into relinquishing its tribal authority to Rhode Island. The tribe did not receive federal recognition until 1983, after the 1934 passage of the IRA. The US Supreme Court agreed with the State.