Indian Dispute. The Second Circuit held that the State of New York legally owned the Niagra River islands. The Seneca Nation claimed that the acquisition of the islands by New York in 1815 from the Seneca Nation of Indians for $1,000 and an annuity of $500 per year was illegal under the Non-Intercouse Act. The Court, however, held that New York had acquired title to the islands prior to the 1815 transaction. It agreed with the District Court's view that Senecas' aboriginal title had been extinguised either pursuant to the 1764 Treaties of Peace between Great Brittain, which transferred title from the Senecas to Great Brittain and the Senecas or by the 1784 Treaty of Fort Stanwix, which extinguished the Seneca's title and passed it to New York. Hence, the 1815 transaction was irrelevant. The decision in Seneca Nation of Indians v. State of New York can be found here.