To say that I am not [Indian] and to prosecute me for telling people of my Indian heritage is to deny me some of my civil liberties...and constitutes racial discrimination." Some critics believe that using federal laws to define "Indian" allows continued government control over Indians, even as the government seeks to establish a sense of deference to tribal sovereignty. Critics say Indianness becomes a rigid legal term defined by the BIA, rather than an expression of tradition, history, and culture. For instance, some groups which claim descendants from tribes that predate European contact have not been able to achieve federal recognition. On the other hand, Indian tribes have participated in setting policy with BIA as to how tribes should be recognized. According to Rennard Strickland, an Indian Law scholar, the federal government uses the process of recognizing groups to "divide and conquer Indians: "the question of who is 'more' or 'most' Indian may draw people away from common concerns." In some cases, one can self-identify about being Native American. For example, one can often choose to identify as Indian without outside verification when filling out a census form, a college application, or writing a letter to the editor of a newspaper. A "self-identified Indian" is a person who may not satisfy the legal requirements which define a Native American according to the United States government or a single tribe, but who understands and expresses her own identity as Native American. However, many people who do not satisfy tribal requirements identify themselves as Native American, whether due to biology, culture, or some other reason. The United States census allows citizens to check any ethnicity without requirements of validation. Thus, the census allows individuals to self-identify as Native American, merely by checking the racial category, "Native American/Alaska Native". In 1990, about 60 percent of the more than 1.8 million persons identifying themselves in the census as American Indian were actually enrolled in a federally recognized tribe. Using self identification allows both uniformity and includes many different ideas of "Indianness". This is practiced by nearly half a million Americans who receive no benefits because   Identity is in some way a personal issue; based on the way one feels about oneself and one's experiences. Horse (2001) describes five influences on self-identity as Indian:  University of Kansas sociologist Joane Nagel traces the tripling in the number of Americans reporting American Indian as their race in the U.S. Census from 1960 to 1990 (from 523,591 to 1,878,285) to federal Indian policy, American ethnic politics, and American Indian political activism.