This article focuses on the U.S. Supreme Court’s recent decision in Carcieri that the Secretary of the Interior does not have the legal authority to place a Rhode Island Indian tribe’s land into trust, because the tribe was not under the jurisdiction of the federal government in 1934, the year that the Indian Reorganization Act (IRA) was signed into law. The ruling, author Claire Hur explains, “might very well affect dozens of tribes recognized after 1934 that are seeking fee-to-trust acquisition with the Secretary.”