Federal monopoly over Indian land dealings predated and outlasted the 1823 ruling.

Evidence

“Indian sales to individuals (as in this case) or to states or any other nation were void,” he concluded in an article in the American Bar Association Journal. “The court confirmed national authority over Indian affairs, which had barred all land and commercial transactions with Indians absent sovereign consent since at least the 1763 British Proclamation, a policy adopted by the First Congress in the 1790 Trade and Intercourse Act.” — Renae Ditmer, Johnson v. M’Intosh, 31

Categorization

• XREF: Echoes the Milgrom law-merchant material: sovereign consent as the gatekeeping institution for otherwise-void transactions.