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In 1786, Thomas Jefferson wrote, "It may be regarded as certain that not a foot of land will ever be taken from the Indians without their consent (PBS)." Forty-Four years later, in 1930, the Unites States Congress passed the Removal Act, which provided funds for the relocation of Indians. Of the tribes to be relocated were the Creek, Choctaw, Chickasaw, Cherokee, and Seminole. Some moved peacefully and others resisted by the use of force, for they believed that it was their land and did not want to stand by while others forced them from their heritage. Natives sought to use the American Court system in court battles like the Cherokee Nation vs. Georgia and Worcester vs. Georgia. The decision made by the Court was that even though the Cherokees were not considered a separate state or nation that they were still a community within a nation. The court ruled that Georgia did not have the right to force the Natives off of their land. This was a ruling that President Jackson refused to enforce and the removal continued. In 1838, the US Army forced the Cherokees west of the Mississippi. They were the last of the Natives to be removed. This is known as the "Trail of Tears". "An estimated 4,000 dies from hunger, exposure and disease; the