The court also ruled in "Reid v. Covert" that treaty provisions that conflict with the US Constitution are null and void under US law. Treaties formed an important part of European colonization and, in many parts of the world, Europeans attempted to legitimize their sovereignty by signing treaties with indigenous peoples. In most cases, these treaties were in extremely disadvantageous terms to the native people, who often did not appreciate the implications of what they were signing. In some rare cases, such as with Ethiopia and Qing Dynasty China, the local governments were able to use the treaties to at least mitigate the impact of European colonization. This involved learning the intricacies of European diplomatic customs and then using the treaties to prevent power from overstepping their agreement or by playing different powers against each other. In other cases, such as New Zealand with the Māori and Canada with its First Nations people, treaties allowed native peoples to maintain a minimum amount of autonomy. Such treaties between colonizers and indigenous peoples are an important part of political discourse in the late 20th and early 21st century, the treaties being discussed have international standing as has been stated in a treaty study by the UN. In the case of Indigenous Australians, no treaty was ever entered into with the Indigenous peoples entitling the Europeans to land ownership, mostly adopting the doctrine of "terra nullius" (with the exception of South Australia). This concept was later overturned by "Mabo v Queensland", which established the concept of native title in Australia well after colonization was already a "fait accompli". On 10 December 2019, the Victorian First Peoples' Assembly met for the first time in the Upper House of the Parliament of Victoria in Melbourne. The main aim of the Assembly is to work out the rules by which individual treaties would be negotiated between the Victorian Government and individual Aboriginal Victorian peoples. It will also establish an independent Treaty Authority, which will oversee the negotiations between the Aboriginal groups and the Victorian Government and ensure fairness. Prior to 1871, the government of the United States regularly entered into treaties with Native Americans but the Indian Appropriations Act of March 3, 1871 (ch. 120, 16 Stat. 563) had a rider () attached that effectively ended the President's treaty-making by providing that no Indian nation or tribe shall be acknowledged as an independent nation, tribe, or power with whom the United States may contract by treaty. The federal government continued to provide similar contractual relations with the Indian tribes after 1871 by agreements, statutes, and executive orders.