 The Indian Appropriations Act also made it a federal crime to commit murder, manslaughter, rape, assault with intent to kill, arson, burglary, or larceny within any Territory of the United States.The Supreme Court affirmed the action in 1886 in "United States v. Kagama", which affirmed that the US Government has plenary power over Native American tribes within its borders using the rationalization that "The power of the general government over these remnants of a race once powerful ... is necessary to their protection as well as to the safety of those among whom they dwell".While the federal government of the United States had previously recognized the Indian Tribes as semi-independent, "it has the right and authority, instead of controlling them by treaties, to govern them by acts of Congress, they being within the geographical limit of the United States ...