In a challenge to the U.S. DOI's decision to take land into trust for the Oneida Indian Nation in present-day New York, Upstate Citizens for Equality (UCE), New York, Oneida County, Madison County, the town of Verona, the town of Vernon, and others argued that the IRA is unconstitutional. Judge Kahn dismissed UCE's complaint, including the failed theory that the IRA is unconstitutional, on the basis of longstanding and settled law on this issue. The US Court of Appeals for the Second Circuit affirmed the dismissal.