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The US Supreme Court had made clear that tribal internal affairs concerning tribal members' individual rights were not covered by the Fifth Amendment to the US constitution. There were other court cases over the following years to continue the thoughts "that tribes were not arms of the federal government when punishing tribal members for criminal acts and that Indian tribes were exempt from many of the constitutional protections governing the actions of state and federal governments." Later, in the 1960s, Congress held a series of hearings on the subject of the authority of tribal governments.