In 1987, in the course of intervening to take over the UKB's
     opportunity to buy an abandoned horserace track in Rogers County called
     Will Rogers Downs, CNO retained a law firm to investigate CNO's legal
     status to determine whether it would be legally possible for CNO to
     engage in a horserace track operation.(DeGeer and Bread, "Federal
     Legislation Affecting Cherokee Nation," Memo to Gene Stipe, Stipe Law
     Firm, McAlester, Oklahoma, 2 November 1987) This evaluation of the legal
     status of Cherokee Nation of Oklahoma as of Fall 1987 surveyed or
     contained:
     * Overview of the history of the laws impacting the Five
     Civilized Tribes
     * 19 Treaties with the U. S. (and limitations imposed therein)
     * Curtis Act of 1898
     * 1901 Cherokee Agreement
     * Cherokee Constitution
     * Jurisdictional Map
     * Solicitor Opinions believed to be pertinent.
     This analysis does not claim that CNO has reorganized under OIWA or IRA,
     referring instead to the 1839 Cherokee Nation Constitution, as
     superseded in the 1976 CNO Constitution, and the legal effect of various
     Acts of Congress preserving or limiting CNO's sovereign authorities. The
     memo describes limitations on the inherent sovereignty of the tribe that
     congressional legislation has imposed since 1898, which only
     reorganization under OIWA and IRA could remedy. The memo does not deal
     with the relationship between the CNO and the UKB, doubtless because the
     authors realized the CNO has no sovereign authority over the UKB.

The memo concluded that CNO's claims to inherent sovereignty are in doubt,
     and the writers recommended that CNO comply with all state laws, as a
     precaution, in any development venture.