The Sacred Buffalo Vision by Robert J. Juneau and Robert C. Juneau pg.170

The patented Indian lands were subsequently lost by the Indians for failure to pay state taxes or through land frauds by agency traders and local white men. Secretarial Sales of Indian Allotments in Heirship Status whereby sales of inherited Indian trust allotments were approved by the Bureau of Indian Affairs without the consent of  beneficial heirs required by 25 U.S.C. Unapproved Rights-Of-Way whereby road and utility line rights-of-way were granted on tribal and allotted lands without the approval of the Indian owners or Secretarial approval. Damages for lost mineral rights and water rights are still undetermined and unresolved.

 Covelo stated “Interior and Justice Depts. Lawyer’s contention that the Executive Branch’s discretion as to whether or not to propose legislation can never be constitutionally limited in light of Article 11, Section 3 is simply erroneous. By signing P.L. 96-217, President Reagan authorized and approved the requirements of Section 2. If the Executive’s discretion was thereby restricted, it was done by his own hand and is, therefore beyond a charge of constitutional infirmity. U.S.C. Sec. 702 provides: A person suffering legal wrong because of agency action, or adversely affected or aggrieved by agency action within the meaning of a relevant statute, is entitled to judicial review.”
-The Sacred Buffalo Vision by Robert J. Juneau and Robert C. Juneau  
pg.170