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While the Indian Removal Act made the relocation of the tribes voluntary, it was often abused by government officials.
The best-known example is the Treaty of New Echota.
It was negotiated and signed by a small faction of Cherokee tribal members, not the tribal leadership, on December 29, 1835.
It resulted in the forced relocation of the tribe in 1838.
An estimated 4, 000 Cherokee died in the march, now known as the Trail of Tears.
Missionary organizer Jeremiah Evarts urged the Cherokee Nation to take their case to the U. S. Supreme Court.
The Marshall court ruled that while Native American tribes were sovereign nations ( Cherokee Nation v. Georgia, 1831 ), state laws had no force on tribal lands ( Worcester v. Georgia, 1832 ).

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