background on CDIB

United States Department of the Interior
OFFICE OF THE SOLICITOR
Tulsa Field Solicitor's Office
7906 East 33rd Street, Suite 100
Tulsa, OK 74145
(918)669-7730
TELEFAX (918) 669-7736

October 22, 1998
MEMORANDUM

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TO:

Deborah Maddox, Director, Tribal Services, BIA

FROM:

M. Sharon Blackwell, Tulsa Field Solicitor

SUBJECT:

Existing Statutes and Regulations Relating to Indian Blood Quantum
INTRODUCTION

In response to your request for participation by our office in addressing legal issues
related to the proposed regulations governing Certificates of Degree of Indian Blood (CDIB),
we have conducted a computerized legal search of various terms related to Indian blood quantum
in the context of federal laws and federal regulations. This search, if not completely exhaustive
of all references to Indian blood quantum in federal laws and regulations, is very close to being
completely exhaustive, and indicates that Indian blood requirements are common in the area of
federal Indian law.

LEGAL ANALYSIS
1. ENROLLMENT AND ENROLLMENT APPEALS

Federal law, 25 U.S.C. § 163, authorizes the Secretary to establish a final membership
roll for a tribe "whenever in his discretion such action would be in the best interest of the
Indian," requires that the roll contain the ages and quantum of Indian blood, and provides that

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"when approved by the said Secretary are declared to constitute the legal membership for the
respective tribes" for the purpose of segregating the tribal funds as provided in 25 U.S.C. § 162,
"and shall be conclusive both as to ages and quantum of Indian blood." Section 163 expressly
excludes the Five Tribes, the Osage Tribe and the Chippewa Indians of Minnesota from its
provisions.
Federal regulations 25 C.F.R. § 61.2 establishes guidelines for preparation of rolls by
the Secretary of Interior "pursuant to statutory authority." These regulations do not apply to
compilation of membership rolls for tribes which have the responsibility for preparation and
maintenance of their membership rolls.

Id.

Under the regulations, the roll should contain

degree of Indian blood for each person when required by law. 25 C.F.R. § 61.14.
Federal regulations also govern appeals of "adverse enrollment actions" by BIA officials
and by tribal committees under two limited circumstances: when the adverse enrollment action
is incident to the preparation of a tribal roll subject to Secretarial approval or when the tribal
governing document requires appeals to the Secretary.

These regulations define "adverse

enrollment actions" as including a change in degree of Indian blood by a tribal committee which
affects a tribal member when the tribal governing document provides for an appeal of the action
to the Secretary, a change in degree of Indian blood by a Bureau official which affects an
individual, and the certification of degree of Indian blood by a Bureau official which affects an
individual. These regulations illustrate the significance of certificates of degree of Indian blood
by referencing them in the procedure for appeals; however, they do not describe the method and
type of documentation needed in making an initial determination of an individual's degree of
Indian blood.

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2. EDUCATIONAL/VOCATIONAL BENEFITS

Eligibility requirements for attendance of federal schools by Indian students include a
"one-fourth or more" degree of Indian blood as a requirement under 25 C.P.R. § 31.1. The
one-quarter blood requirement is also contained in 25 C.P.R. § 32.4(z) for purposes of Indian
education policies, as follows (emphasis added):
(z) Eligibility for services. Serve Indian and Alaska Native students who are
recognized by the Secretary of the Interior as eligible for Federal services, because of
their status as Indians or Alaska Natives, whose Indian blood quantum is 1/4 degree or
more...
See also 25 U.S.C. § 2007(f) (defining"eligible Indian student" as a member or a descendent of
"at least a 1/4 degree Indian blood).

The quarter blood quantum requirement is also

included in 25 C.P.R. § 36.3 for purposes of regulation of academic standards for basic
education of Indian children, as follows (emphasis added):
"Indian student" means a student who is a member of an Indian tribe and is one­
quarter (1/4) or more degree of Indian blood quantum.
The quarter blood quantum requirement is also included

In

25 C.F.R. § 40.1 for

educational and vocational loans to students who reside on reservation, as well as students who
reside near the reservation "when a denial of such loans or grants would have a direct effect
upon Bureau programs within the reservation."

It is also included for purposes of Adult

Education programs under 25 C.F.R. § 46.2, which states (emphasis added):
Indian means a person who is a member of, or is at least a one-fourth degree
Indian blood descendent of a member of, an Indian tribe, and is eligible for the special
programs and services provided by the United States through the Bureau of Indian Affairs
to Indians because of their status as Indians;
A blood quantum requirement is included in 25 C.P.R. § 273.12 for student eligibility
for educational benefits provided under Johnson O'Malley Act contracts, as follows (emphasis
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added):
Indian students, from age 3 years through grade(s) 12, except those who are
enrolled in Bureau or sectarian operated schools, shall be eligible for benefits provided
by a contract pursuant to this part if they are 1/4 or more degree Indian blood and
recognized by the Secretary as being eligible for Bureau services. Priority shall be given
to contracts (a) which would serve Indian students on or near reservations and-(b) where
a majority of such Indian students will be members of the tribe(s) of such reservations
(as defined in 273.2(0».
Methods of establishing eligibility for Indian Fellowship and Professional Development
Programs are described in 34 C.F.R. § 263.21(a) as follows (emphasis added):
(a) Evidence that the applicant is an Indian as defined in § 263.3. Evidence may
be in the form of-­
(1)(i)
A copy of the applicant's documentation of tribal enrollment or
membership; or
(ii) A copy of a parent's or grandparent's documentation of tribal enrollment or
membership, with supporting birth certificates or similar documents showing the
applicant's descendance from the enrolled member;
(2) A letter of certification on official letterhead with the appropriate signature
from a federally or State recognized tribe or band; or
(3) A certificate of degree of Indian blood (CDIB) issued by an authorized
representative of the Bureau of Indian Affairs or an official of a federally recognized
tribe;
3.

EMPWYMENT ASSISTANCE, VOCATIONAL TRAINING, AND INDIAN
HIRING PREFERENCE
The term "Indian" as defined in 25 C.F.R. § 26.1(G) for purposes of the Employment

Assistance Program and as defined in 25 C.F.R. § 27. 1(i) for purposes of vocational training
includes blood quantum requirements as follows (emphasis added):
(b) "Indian" means any person of Indian or Alaska native descent who is an

enrolled member of any of those tribes listed or eligible to be listed in the Federal
Register pursuant to 25 C.F.R. § 83.6 as recognized by and receiving services from the
Bureau of Indian Affairs or a descendant of one-fourth degree or more Indian blood of
an enrolled member; and any person not a member of one of the listed or eligible to be
listed tribes who possesses at least one-half degree of Indian blood which is not derived
from a tribe whose relationship is terminated by an Act of Congress.

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Indian preference requirements do not appear to require membership in a federally
recognized Indian tribe. For example, 25 C.F.R. § 5.1 list persons who may receive Indian
hiring preference within the BIA as follows (emphasis added):
For purposes of making appointments to vacancies in all positions in the Indian
Health Service a preference will be extended to persons of Indian descent who are:
(a) Members of any recognized Indian tribe now under Federal jurisdiction;
(b) Descendants of such members who were, on June 1, 1934, residing within
the present boundaries of any Indian reservation;
(c) All others ofone-halfor more Indian blood oftribes indigenous to the United
States;
(d) Eskimos and other aboriginal people of Alaska; and
(e) For one (1) year or until the Osage Tribe has formally organized, whichever
comes first, effective January 5, 1989, a person of at least one-quarter degree Indian
ancestry of the Osage Tribe of Indians, whose rolls were closed by an act of Congress.
Provisions governing Indian preference within the Public Health Service, 42 C.P.R. §
36.41 , contain similar provisions. 1
4. SOCIAL SERVICES AND LOANS
For purposes of determining eligibility for financial assistance and social services
programs, there is a blood quantum requirement only for Alaska natives and Oklahoma Indians
pursuant to 25 C.F.R. § 20.20(a)(1), which states (emphasis added):
(1) The applicant must be an Indian, except that in the States of Alaska and
Oklahoma a one-fourtli degree or more Indian or Native blood quantum will be an
additional eligibility requirement. ..
The term "Indian" is defined in 25 C.F.R. § 20.l(n) for purposes of financial assistance
and social services programs to include a blood quantum requirement, as follows (emphasis

1 The main difference appears in sub-section (e) of 42 CFR § 36.41, which provides: "(e)
Until January 4, 1990 or until the Osage Tribe has formally organized, whichever comes first,
a person of at least one-quarter degree Indian ancestry of the Osage Tribe of Indians, whose rolls
were closed by an act of Congress. "

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added):
(n) "Indian" means any person who is a member, or a one-fourth degree or more
blood quantum descendant of a member of any Indian tribe.
Federal law, 25 U.S.C. § 480, provides that on and after May 10, 1939, "no individual
of less than one-quarter degree of Indian blood" is eligible for a loan of funds made available
in accordance with several other laws. Revolving loan funds also cannot be loaned to "Indians
of less than one-quarter Indian blood." 25 U.S.C. § 482.

5. LAND ALLOTMENTS; NATURAL RESOURCES
The term "individual Indian" is defined in 25 C.P.R. § 151.2(c) for purposes of
acquisitions of land in trust as follows (emphasis added):
(1) Any person who is an enrolled member of a tribe;
(2) Any person who is a descendant of such a member and said descendant was, on June
1, 1934, physically residing on a federally recognized Indian reservation;
(3) Any other person possessing a total of one-half or more degree Indian blood of a
tribe;

Provisions defining "Indian" for purposes of protection of Indians and conservation of
resources, 25 U.S.C. § 479, contain similar, but not identical, provisions, including reference
to "all other persons of one-half or more Indian blood. "
Eligibility for an allotment of land from the public domain is governed in part by Indian
status under 43 C.P.R. § 2531.1(b), which requires that any person desiring to file an
application for an allotment of land on the public domain "must first obtain from the
Commissioner of Indian Affairs a certificate showing that he or she is an Indian and eligible for
such allotment." The certificate is required to bear a serial number, "record thereof to be kept
in the Indian Office," and required forms must be obtained "as stated in § 2531.2(b)." Sub­
section (e) provides that the eligibility for allotments of Indian women married to non-Indians
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"will be determined without reference to the quantum of Indian blood possessed by such
women," but solely with reference as to whether they are recognized members of an Indian tribe
or are entitled to such membership. 43 C.F.R. § 2531.1(e).
A definition of "Indian individual" is contained in 25 C.F.R. § 262.2(d) for regulation
of the protection of archaeological resources, including a blood quantum requirement, as follows
(emphasis added):
(1) Any person who is an enrolled member of a Federal recognized Indian tribe;
(2) Any person who is a descendent of such a member and was, on June 1, 1934,
physically residing within the present boundaries of any Indian reservation; or
(3) Any other person ofone-halfor more Indian blood oftribes indigenous to the United
States.
6. TRIBAL REORGANIZATION

A definition of "Indian" contained in 25 C.F.R. § 81.1 (i), for purposes of tribal
reorganization, includes a blood quantum requirement as follows (emphasis added):
(i) "Indian" means (1) All persons who are members of those tribes listed or
eligible to be listed in the FEDERAL REGISTER pursuant to 25 C.F.R. § 83.6(b) as
recognized by and receiving services from the Bureau of Indian Affairs; provided, that
the tribes have not voted to exclude themselves from the Act of June 18, 1934, 43 Stat.
984, as amended; and (2) any person not a member of one of the listed or eligible to be
listed tribes who possesses at least one-half degree of Indian blood.
A blood quantum requirement is also contained in one of the definitions of "tribe" for
purposes of tribal reorganization set forth in § 81.1(w) (emphasis added):
... (2) any group of Indians whose members eadi have at least one-half degree
of Indian blood for whom a reservation is established and who each reside on that
reservation. Such tribes may consist of any consolidation of one or more tribes or parts
of tribes.

7. HOUSING

Requirements for the housing assistance improvement program set forth in 25 C.F.R. §

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256.13 allow use of CDIB to establish Indian status as follows (emphasis added):
(d) Fourth, you must furnish documentation proving tribal membership.
Examples of acceptable documentation include a copy of your Certificate of Degree of
Indian Blood (CDIB) or a copy of your tribal membership card.

8. LICENSED INDIAN TRADER
Under 25 U.S.c. § 264 and 25 C.F.R. § 140.3, any "person other than an Indian of the
full blood" attempting to reside in Indian country as a trader without a license, is required to
forfeit all merchandise offered for sale to the Indians, except persons residing among or trading
with the Five Tribes.

9. BLOOD QUANTUM REQUIREMENTS FOR INDIVIDUAL TRIBES
A. Oklahoma Tribes
1. Five Tribes

The degree of Indian blood of members of the Five Civilized Tribes (i.e., Cherokee,
Chickasaw, Seminole, Muskogee-Creek and Choctaw Nations, hereinafter referred to as "Five
Tribes") is determinative of the restricted or unrestricted lands owned by tribal members.
Throughout this century, there have been a number of laws which define restricted status of
Indian lands according to Indian blood quantum. See Act of April 6, 1906, 34 Stat. 137, § 19;
Act of May 27, 1908, 35 Stat. 312, § 1; Act of June 14, 1918, 40 Stat. 606, § 2; Act of May
10, 1928, 45 Stat. 495, § 1.
The most recent of these laws, the Act of August 4, 1947, 61 Stat. 731, currently
governs the restricted status of thousands of acres of Indian lands in eastern Oklahoma. Section
l(a) of the 1947 Act provides (emphasis added):
(a) That.. .no conveyance, including an oil and gas or mineral lease, of any
interest in land acquired before or after the date of this Act by an Indian heir or devisee
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of one-halfor more Indian blood, when such interest in land was restricted in the hands
of the person from whom such Indian heir or devisee acquired same, shall be valid unless
approved in open court by the county court of the county in Oklahoma in which the land
is situated....
Section 2 of the 1947 Act requires use of the final rolls developed by federal officials
during the allotment process at the beginning of the twentieth century to determine blood
quantum for purposes of the restricted status of lands belonging to Five Tribes members, but it
does not necessarily apply to tribal determinations of Indian blood quantum for other purposes.
Section 2 provides (emphasis added):
In determining the quantum of Indian blood of any Indian heir or devisee, the
final rolls of the Five Civilized Tribes as to such heir or devisee, if enrolled, shall be
conclusive of his or her quantum of Indian blood. If unenrolled, his or her degree of
Indian blood shall be computed from the nearest enrolled paternal and maternal lineal
ancestors of Indian blood enrolled on the final rolls of the Five Civilized Tribes.
Federal law authorizes leasing of restricted lands belonging to Five Tribes members "of
one-half or more Indian blood," only under rules and regulations established by the Secretary
of Interior. 25 U.S.C. § 393a (emphasis added).
Regulations governing the creation of trusts for restricted property of members of the
Five Tribes, 25 C.P.R. § 116.4, contain a one-half degree of Indian blood quantum requirement
consistent with the 1947 Act, requiring the following provision in the trust agreement (emphasis
added):
(a) That such of the current income from the corpus of the estate as may be
payable to the Indians of the Five Civilized Tribes ofone-halfor more Indian blood shall
be remitted by the trustee to the Secretary of the Interior or such other official as he may
designate for appropriate disposition.
Regulations concerning leasing of restricted lands of members of the Five Civilized
Tribes of Oklahoma for mining, 25 C.F.R. § 213.45, set standards for lands acquired by

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"persons of one-half or more Indian blood," by "full blood Indians," by "Indians of less than
full blood," and by "heirs of one-half or more Indian blood but less than full bloods. "

2. Osage Tribe
With a few exceptions," federal regulations governing Osage members generally contain
a one-half degree of Indian blood requirement for a variety of purposes.

See 25 C.F.R. §

117.26 (extension of credit for certain purposes pending qualification of personal representative
of an estate of a deceased Indian "of one-half or more Indian blood" who did not have a
certificate of competency at his death"); § 117.27(a) (certain payments to personal representative
of the estate of a deceased Indian "of less than one-half Indian blood who had a certificate of
competency;" § 117.27(b) (payment of certain classes of judgment funds to personal
representative of the estate of a deceased "Indian of one-half or more Indian blood" who did not
have a certificate of competency); § 117.28 (payment of certain claims against the estate of "a
deceased Indian of one-half or more Indian blood" who had no certificate of competency); and
§ 152.9 (issuance of certificates of competency to adult members of the Osage Tribe "of one-half

or more Indian blood").
Federal regulations rely heavily on BIA records for purposes of determining blood
quantum of Osage persons for purposes of preparation of a competency roll for unallotted

2 Federal law governing disposition of Osage judgment funds, 25 U.S.C. §§ 883, 883a,
883b, reference allottees and heirs of Osage blood, and contain no blood quantum requirements.
Consistent with federal law, the definition of an Osage tribal member contained in 25 C.F.R.
§ 91.2 expressly eliminates an Indian blood quantum as follows: (d) 'Tribal Member' means any
person of Osage Indian blood of whatever degree, allotted or unallotted. " See also 121. 3 (claims
by "heirs of Osage Indian blood of deceased allottees); See also 25 C.F.R. §§ 121.5, 121.6,
121.9 (referencing "heirs of Osage Indian blood" with regard to judgment fund distributions);
and § 122.5 (Osage Indian blood requirement for members of Osage Tribal Education
Committee).

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members of the Osage Tribe "of less than one-half Indian blood" who has not received a
certificate of competency. See 25 C.P.R. §§ 154.1 - 154.5. The competency roll must include
the "total quantum of Osage blood and non-Osage Indian blood" of each person listed on the
competency roll. 25 C.P.R. § 154.2. In certain circumstances, the Osage Agency register of
Indian families for the year ending December 31, 1901, must be accepted "as prima facie
evidence of the quantum of Indian blood." 25 C.P.R. § 154.3(b)(1) and (2). Where Indian
blood of a different tribe is involved, "the certification of the superintendent or other officer in
charge" of the Indian Agency having jurisdiction over the affairs of that tribe "shall be accepted
as prima facie evidence in determining the quantum of non-Osage Indian blood." 25 C.P.R. §
154.3(b)(3). If the superintendent or other officer in charge of the other Agency is unable to
certify as to the quantum of Indian blood of a non-Osage parent of an unallotted Osage member
ofless than one-halfIndian blood, "affidavits as to such parent's quantum ofIndian blood, when
properly executed by two qualified individuals, may be accepted." 25 C.P.R. § 154.3(b)(4).
The federal regulations governing the Osage competency roll contain provisions affording
due process to a person, when the superintendent determines that the person is of less than one­
half Indian blood. The superintendent must notify that person and inform the person that if
objection is not received within 20 days from date of notification a certificate of competency will
be used. 25 C.F.R. §154.4. The party may dispute the finding by submitting "two affidavits
or other evidence in support of his claim." The "claim affidavits or other evidence of the person
as to his quantum of blood" must be submitted to the Commissioner of Indian Affairs "for a
ruling before the certificate of competency is issued. "

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B. Alaskan Tribes
While some federal laws and regulations concerning Alaskan Natives have no blood
quantum requirements," the Alaska Claims Settlement Act, 43 U.S.C. § l602(b) includes a
blood quantum requirement in its definition of "Native" for its purposes as follows: _
"Native" means a citizen of the United States who is a person of one-fourth
degree or more Alaskan Indian (including Tsimshian Indians not enrolled in the Metlaktla
Indian Community), Eskimo, or Aleut blood, or a combination thereof. The term
includes any Native as so defined either or both of whose adoptive parents are not
Natives. It also includes, in the absence of proof of a minimum blood quantum, any
citizen of the United States who is regarded as an Alaska Native by the Native village
or Native group of which he claims to be a member and whose father or mother is (or,
if deceased, was) regarded as Native by any village or group. Any decision of the
Secretary regarding eligibility for enrollment shall be final;
Other definitions of Alaskan Natives contained in various federal regulations are not
identical, but contain similar blood quantum requirements: 13 C.P.R. § 124.100 (minority small
business and capital ownership development); 50 C.P.R. § 17.3 (concerning endangered wildlife
and plants); 50 C.P.R. § 18.3 (relating to sale of marine mammals); and 50 C.F.R. § 216.3
(regulating the taking and importing of marine mammals).

See also 43 C.P.R. § 2561.0-3

(degree of Indian blood is irrelevant to rights related to native allotments by an Indian who
resides in Alaska); 43 C.F.R. § 4300.0-5.

C. Canadian Born Indians
Federal law, 25 U.S.C. § 1359 contains the following blood quantum requirement for
Indians born in Canada who cross the border (emphasis added):
Nothing in this subchapter shall be construed to affect the right of American

3 Federal law, 25 U.S.C. § 500n, defines a "native of Alaska" as including native Indians,
Eskimos and Aleuts "of whole or part blood," for purposes of laws governing a reindeer
industry.

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Indians born in Canada to pass the borders of the United States, but such right shall
extend only to persons who possess at least 50 per centum of blood of the American
Indian race.
Federal immigration regulations, 8 C.F.R. § 289.1, provide (emphasis added):
The term "American Indian born in Canada" as used in section 289 of the Act
includes only persons possessing 50 per centum or more of the blood of the American
Indian race. It does not include a person who is the spouse or child of such an Indian or
a person whose membership in an Indian tribe or family is created by adoption, unless
such person possesses at least 50 per centum or more of such blood.
Other federal regulations governing visa and passport requirements as applied to nonimmigrants, 22 C.F.R. §§ 41.1(b) and 42.1(f), define the term "American Indians born in
Canada," as (emphasis added):
... An American Indian born in Canada, having at least 50 per centum of blood of the
American Indian race (Sec. 289, 66 Stat. 234; 8 U.S.C. 1359).
The Legal Services Corporation regulations, 45 C.F.R. § 1626.10 also include a blood
quantum requirement for eligibility for legal aid to Indians born in Canada as follows (emphasis
added):
All Canadian-born American Indians at least 50% Indian by blood are
eligible to receive legal assistance provided they are otherwise eligible under the Act.
(b)

D. Other Specified Tribes
The following laws and regulations include blood quantum requirements related to
enrollment of members of specific Indian tribes for judgment fund distribution purposes, as
follows: 25 U.S.C. § 585 (Northwestern Bands of Shoshone Indians); 25 U.S.c. §§ 961, 967a
(descendants of allottees of Omaha Tribe who possess" Omaha blood ofthe degree ofone-fourtli

or more"); 25 U.S.C. § 1142 (New York Indians, including those who are Brotherton Indians
of Wisconsin of at least one-fourth. degree Emigrant New York Indian blood ... ") Federal law

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also has included blood quantum requirements with regard to specific tribes for many other
purposes."
CONCLUSION

Currently existing federal laws and regulations require some form of proof of Indian
blood for various purposes. Some of these regulations even expressly refer to Certificates of
Degree of Indian blood. Unless these laws and regulations are amended to eliminate the need
for a method of proving Indian blood or Indian blood quantum, uniform standards for issuance,
amendments and denials of Certificates of Degree of Indian blood are essential for compliance
with the law.

4 See 25 U.S.C. §§ 677, 677a(b)(defining a "full-blood" as a tribal member who possesses
"one-half degree of Ute Indian blood and a total of Indian blood in excess of one-half') and
677a(c) (defining a "mixed-blood" as a tribal member who does not possess sufficient Indian or
Ute Indian blood to fall within the full-blood class, and those who became mixed-bloods by
choice). See also 25 U.S.C. §§ 677v, 677w, 677aa (relating to partition and distribution of tribal
assets between mixed blood and full blood members of the Ute Indians of Utah); 25 U.S.C. §
715e (one-eighth blood quantum requirement for compilation of membership rolls relating to
restoration of federal supervision over Coquille Indian Tribe of Oregon); 25 U.S.C. § 903b(c)
(updating of Menominee Tribe membership roll, and requiring a one-quarter degree of
Menominee Indian blood for heirs of allottees); 25 U.S.c. § 971 (termination of federal
supervision and distribution of tribal assets to persons on membership roll of the Ponca Tribe
of Nebraska, including descendants of enrollees"of not less than one-quarter degree Indian blood
of the Ponca Tribe"); 25 U.S.C. § 1300g-7(a) (restoration of supervision over Ysleta Del Sur
Pueblo and definition of tribal members, including descendant of an enrollee who has "1/8 or
more degree" of Tigua-Ysleta del Sur Pueblo Indian blood); 25 U.S.C. § 1300 h-3 (federal
recognition of Lac Vieux Desert Band of Lake Superior Chippewa, and establishment of
membership roll, including persons who are "at least one-quarter Chippewa Indian blood ... If);
25 C.F.R. § 61.4 (preparation of rolls of various Tribes, some of which have blood quantum
requirements); 25 C.F.R. § 75.6 (revision of rolls of Eastern Band of Cherokee Indians, North
Carolina); 25 C.F.R. § 153.3 (degree of Indian blood required on enrollment application for
Crow Tribe); and 25 U.S.C. § 1300i-5(3) ("The Secretary shall determine the quantum of
'Indian blood' or 'Hoopa Indian blood, 'if any, of each person enrolled in the Hoopa Valley
Tribe under this subsection pursuant to the criteria established in the March 31, 1982 decision
of the United States Court of Claims in the case of Jesse Short et al. v. United States, (CL.Ct.
No. 102-63).

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If you have questions related to this memorandum, please contact me at (918) 669-7730,

ext. 228.

FIELD SOLICITOR

L. Susan Work

Attorney

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