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Congress has always exercised control over Native American' peoples through its plenary powers.2 In 1968, that control took the form of the Indian Civil Rights Act (ICRA).3 The ICRA represents a congressional decision to limit Native American sovereignty by setting forth an Indian Bill of Rights that applies to Native American tribes.4 It is Congress' effort to protect individuals from tribal abuses. By designing a special Indian Bill of Rights,5 Congress

Tribal Courts' Failure to Protect Native American Women: A Reevaluation of the Indian Civil Rights Act