Russell Means, founder of the American Indian Movement, longtime activist on issues of Native American sovereignty, and an Oglala Sioux, angered many other Native Americans by arguing, in his trial for assault, that the Navajo Court hearing the case had no legitimate standing. Under a 1991 law, Congress gave Indian tribes the right to prosecute Indians who were members of other tribes. But lawyers for Means argued that since the Supreme Court ruled that Indians can't prosecute non-Indians, to allow his prosecution because he was an Indian discriminated against him because he was not, say, white or black.

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