Congress quickly addressed the jurisdictional gap that emerged from the Court's ruling by amending the Indian Civil Rights Act in 1990 as part of the Department of Defense Appropriations Act of 1991, which was signed into law on November 5, 1990.[8][9] Nearly fourteen years later, the Supreme Court ruled on the constitutionality of this amendment to 25 U.S.C. § 1301(2) in United States v. Lara (2004), upholding the amendment to the Indian Civil Rights Act and effectively overturning Duro v. Reina.