Thus, states may not impose taxes on transactions between members that take place on reservations, because this would interfere with the sovereignty of tribes vis-à-vis their own members. Tribes also retain the power to regulate hunting on lands they own or lands held in trust for them by the United States, but not on lands held in fee. And although other decisions of the Court had recognized broader retained powers in the civil context, criminal powers of Indian tribes were strictly limited to members because "the exercise of criminal jurisdiction subjects a person not only to the adjudicatory power of the tribunal, but also to the prosecuting power of the tribe, and involves a far more direct intrusion on personal liberties."