The Kiowa leader Lone Wolf fights allotment policy all the way to the Supreme Court (Lone Wolf v. Hitchcock) in an attempt to prevent break-up of Kiowa lands promised in the Medicine Lodge Treaty. However, the Supreme Court, in their decision ruling against Lone Wolf, create the concept of “plenary powers” where they deem Congress to have the power to abrogate, ignore, or change Indian treaties without interference from the courts or judicial review (Nies, 1996).