OCTOBER TERM, 1997
Syllabus
CASS COUNTY, MINNESOTA, ET AL.
v. LEECH LAKE BAND OF
CHIPPEWA INDIANS
CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR THE EIGHTH
CIRCUIT
No. 97-174. Argued February 24, 1998-Decided June 8,1998
During the late 19th century, the Federal Government instituted
a policy of removing portions of reservation land from tribal
ownership and federal protection, allotting some parcels to
individual Indians in fee simple and providing for other parcels to
be sold to non-Indians. Most allotments were implemented pursuant
to the General Allotment Act (GAA), which provided that land would
be patented to individual Indians and held in trust for 25 years,
after which title would be conveyed in fee simple, § 5, and that
Indian allottees were subject to plenary state jurisdiction, § 6.
The Burke Act amended § 6 to provide that state jurisdiction did
not attach until the end of the trust period, and contained a
proviso to the effect that the Secretary of the Interior could
issue a fee simple patent before the trust period's end and
thereafter restrictions as to,
inter alia, taxation would be
removed. Allotment of the Minnesota reservation lands of respondent
Leech Lake Band of Chippewa Indians (Band) was implemented through
the Nelson Act of 1889, which provided for the reservation land to
be alienated from tribal ownership in three ways: under § 3,
parcels were allotted to individual Indians as provided by the GAA;
under §§4 and 5, pine lands were sold at public auction to
non-Indians; and under § 6, agricultural lands were sold to
non-Indian settlers as homesteads. After Congress ended the
allotment practice, the Band began purchasing back parcels of
reservation land that had been allotted to individual Indians or
sold to non-Indians. Based on this Court's decision, in
County
of Yakima v.
Confederated Tribes and Bands of Yakima
Nation, 502 U. S.
251, 253-254, that a county could assess ad valorem taxes on
reservation land owned in fee by individual Indians or the tribe
that had originally been made alienable when patented under the
GAA, petitioner Cass County began assessing such taxes on 21
parcels of reservation land that had been alienated under the
Nelson Act and reacquired by the Band. Thirteen of the parcels had
been allotted to Indians and the remaining eight had been sold to
non-Indians. The Band paid the taxes, interest, and penalties under
protest and filed suit seeking a declaratory judgment that the
county could not tax the parcels. The District Court granted the
county summary judgment, holding that the parcels were taxable
be-
104
Syllabus
cause, under
Yakima, if Congress has made Indian land
freely alienable, States may tax the land. The Eighth Circuit
affirmed in part and reversed in part, holding that the parcels
allotted to Indians could be taxed if patented under the Burke Act
proviso, which made "unmistakably clear" Congress' intent to allow
such taxation, but that the eight parcels sold to non-Indians could
not. Only those eight parcels are at issue here.
Held: State and local governments may impose ad valorem
taxes on reservation land that was made alienable by Congress and
sold to nonIndians, but was later repurchased by the tribe. Pp.
110-115.
(a) Congress' intent to authorize state and local taxation of
Indian reservation land must be "'unmistakably clear.'''
Yakima,
supra, at 258. Congress has manifested such an intent when it
has authorized reservation lands to be allotted in fee to
individual Indians, making the lands freely alienable and
withdrawing them from federal protection. This was the case in both
Yakima and
Goudy v.
Meath, 203 U. S. 146. The
Goudy Court concluded that, because it would be unreasonable
for Congress to withdraw federal protection and permit an Indian to
dispose of his lands as he pleased, while releasing the lands from
taxation, Congress would have to "clearly manifest" such a contrary
purpose in order to counteract the consequence of taxability that
ordinarily flows from alienability.
Id., at 149. The
Yakima Court found that both the Burke Act proviso and § 5
of the GAA manifested an unmistakably clear intent to allow state
and local taxation of allotted land. The Eighth Circuit thus erred
in concluding that
Yakima turned on the Burke Act proviso's
express reference to taxability. Both it and
Goudy stand for
the proposition that when Congress makes reservation lands freely
alienable, it is unmistakably clear that Congress intends that land
to be taxable by state and local governments, unless a contrary
intent is "clearly manifested."
Yakima, supra, at 259. Pp.
110-113.
(b) The foregoing principle controls the disposition of this
case. By providing for the public sale of reservation land to
non-Indians in the Nelson Act, Congress removed that land from
federal protection and made it fully alienable. Under
Yakima
and
Goudy, therefore, it is taxable. The Eighth Circuit's
contrary holding attributes to Congress the odd intent that parcels
conveyed to Indians are taxable, while parcels sold to the general
public remain tax exempt. Contrary to the Band's argument, a
tribe's subsequent repurchase of alienable reservation land does
not manifest any congressional intent to reassume federal
protection of the land and to oust state taxing authority,
particularly when Congress relinquished such protection many years
before. Further,
105
holding that tax-exempt status automatically attaches when a
tribe acquires reservation land would render unnecessary § 465 of
the Indian Reorganization Act, which gives the Secretary of the
Interior authority to place land in trust, held for the Indians'
benefit and tax exempt, and which respondent has used to restore
federal trust status to seven of the eight parcels at issue. Pp.
113-115.
108 F.3d
820, reversed in part.
THOMAS, J., delivered the opinion for a unanimous Court.
Earl E. Maus argued the cause for petitioners. With him
on the briefs were
Mark B. Levinger and
James W
Neher, Assistant Attorneys General of Minnesota.
James M. Schoessler argued the cause for respondent.
With him on the brief were
Steven G.
Thorne and
Joseph
Barbara McDowell argued the cause for the United States as
amicus curiae urging affirmance. With her on the brief were
Solicitor General Waxman, Assistant Attorney General Schiffer,
Deputy Solicitor General Kneedler, and James C. Kilbourne. *
*Briefs of
amici curiae urging reversal were filed for
the State of Michigan et al. by
Frank J.
Kelley,
Attorney General of Michigan,
Thomas L. Casey, Solicitor
General, and
R. John Wernet, Jr., Assistant Attorney
General, and by the Attorneys General for their respective States
as follows:
Bill Pryor of Alabama, Daniel E. Lungren of California, Gale A.
Norton of Colorado, Alan G. Lance of Idaho, Thomas J. Miller of
Iowa, Joseph P. Mazurek of Montana, Dennis C. Vacco of New York, W
A. Drew Edmondson of Oklahoma, and Jan Graham of Utah; for Lewis
County, Idaho, et al. by Tom D. Tobin, James M. Johnson, Kimron
Torgerson, Michael Jesse, and Herbert Wm. Gillespie; and for the
National Association of Counties et al. by Richard Ruda and Carter
G. Phillips.
Briefs of
amici curiae urging affirmance were filed for
the Confederated Tribes and Bands of the Yakama Indian Nation by
Tim Weaver; for the Grand Portage Band of Chippewa et al. by
Vanya S.
Hogen-Kind; for the Hoopa Valley Tribe et
al. by
Michael J.
Wahoske; for the Lummi Indian Tribe
by
Harry L. Johnsen III and
Judith K. Bush; for the
Saginaw Chippewa Indian Tribe of Michigan by
Frank R.
Jozwiak and
K. Allison
106
JUSTICE THOMAS delivered the opinion of the Court.
We granted certiorari in this case to resolve whether state and
local governments may tax reservation land that was made alienable
by Congress and sold to non-Indians by the Federal Government, but
was later repurchased by a tribe. We hold that ad valorem taxes may
be imposed upon such land because, under the test established by
our precedents, Congress has made "unmistakably clear" its intent
to allow such taxation.
I
The Leech Lake Band of Chippewa Indians is a federally
recognized Indian tribe. The Leech Lake Reservation, which today
encompasses 588,684 acres within the northern Minnesota counties of
Cass, Itasca, and Beltrami, was established by federal treaty in
1855 and was augmented by subsequent treaties and Executive
Orders.
During the late 19th century, the Federal Government changed its
policy of setting aside reservation lands exclusively for Indian
tribes under federal supervision. The new "allotment" policy
removed significant portions of reservation land from tribal
ownership and federal protection, allotting some parcels to
individual Indians and providing for other parcels to be sold to
non-Indians. See
County of Yakima v.
Confederated Tribes
and Bands of Yakima Nation, 502 U. S. 251, 253-254
(1992); F. Cohen, Handbook of Federal Indian Law 127-138 (1982).
The purpose of the policy was to assimilate Indians into American
society and to open reservation lands to ownership by non-Indians.
Id., at 128.
Most of the allotments made by the Federal Government were
implemented pursuant to the General Allotment Act of
McGaw; and for the National Congress of American Indians
by
Tracy A. Labin and
Kim Jerome Gottschalk.
Briefs of
amici curiae were filed for the Citizens Equal
Rights Alliance by
Douglas Y.
Freeman; for the Oneida
Indian Nation of New York by
William W Taylor III and
Michael R. Smith; and for the Tribes of Forest County
Potawatomi Community et al. by
Carol Brown Biermeier.
107
1887 (GAA), 24 Stat. 388, as amended, 25 U. S. C. § 331
et
seq. Section 5 of the GAA provided that parcels of tribal land
would be patented to individual Indians and held in trust by the
United States for a 25-year period, after which the Federal
Government would convey title to the individual allottees-
"in fee, discharged of said trust and free of all charge or
incumbrance whatsoever .... And if any conveyance shall be made of
the lands set apart and allotted as herein provided, or any
contract made touching the same, before the expiration of the time
above mentioned, such conveyance or contract shall be absolutely
null and void .... " 25 U. S. C. § 348.
Section 6 of the GAA, as originally enacted in 1887, provided
that "each and every member of the respective bands or tribes of
Indians to whom allotments have been made shall have the benefit of
and be subject to the laws, both civil and criminal, of the State
or Territory in which they may reside." 24 Stat. 388. In 1905, this
Court interpreted § 6 to mean that Indian allottees were subject to
plenary state jurisdiction immediately upon issuance of the trust
patent. See
In re Heff,
197 U. S. 488.
The following year, Congress reversed the result of
In re
Heff by passing the Burke Act, 34 Stat. 182, 25 U. S. C. § 349,
which amended § 6 of the GAA to provide that state jurisdiction did
not attach until the end of the 25-year trust period, when the
lands were conveyed to the Indians in fee. The Burke Act also
contained a proviso to the effect that the Secretary of the
Interior could, if "satisfied that any Indian allottee is competent
and capable of managing his or her affairs," authorize issuance of
a fee simple patent to the land before the end of the usual trust
period, "and thereafter all restrictions as to sale, incumbrance,
or taxation of said land shall be removed .... "
Ibid.
108
For the Leech Lake Band and other Chippewa Tribes in Minnesota,
the allotment policy was implemented through the Nelson Act of
1889. 25 Stat. 642. The Nelson Act provided for the "complete
cession and relinquishment" of tribal title to all reservation land
in the State of Minnesota, except for parts of two reservations, to
the United States. After such "complete cession and
relinquishment," which "operate[d] as a complete extinguishment of
Indian title," the lands were to be disposed of in one of three
ways: under § 3, the United States would allot parcels to
individual tribe members as provided in the GAA; under §§ 4 and 5,
so-called "pine lands" (surveyed 40-acre lots with standing or
growing pine timber) were to be sold by the United States at public
auction to the highest bidder; and under § 6, the remainder of the
reservation land (called "agricultural lands") was to be sold by
the United States to non-Indian settlers under the provisions of
the Homestead Act of 1862, 12 Stat. 392.
In 1934, federal Indian policy shifted dramatically when
Congress enacted the Indian Reorganization Act, 48 Stat. 984,25 U.
S. C. § 461
et seq., which ended the practice of making
federal allotments to individual Indians. Although the
Reorganization Act did not repeal allotment statutes such as the
Nelson Act, it extended the trust period for lands already allotted
but not yet fee patented, provided that unallotted surplus lands
would be restored to tribal ownership, and allowed additional lands
"within or without existing reservations" to be acquired by the
Federal Government for the tribes. See §§ 461, 462, 463, 465.
In 1977, the Leech Lake Band and individual Band members owned
only about 27,000 acres-less than five percentof Leech Lake
Reservation land. See
State v.
Forge, 262 N. W. 2d
341, 343, and n. 1 (Minn. 1977). Since then, the Leech Lake Band
has sought to reestablish its land base by purchasing back parcels
of reservation land that were allotted to individual Indians or
sold to non-Indians during the allotment period.
109
In 1992, we held in
County of Yakima v.
Confederated
Tribes and Bands of Yakima Nation, supra, that a county could
assess ad valorem taxes on reservation land owned in fee by
individual Indians or the tribe and originally made alienable when
patented in fee simple under the GAA.
In 1993, Cass County began assessing ad valorem taxes on 21
parcels of reservation land that had been alienated from tribal
control under the various provisions of the Nelson Act and later
reacquired by the Leech Lake Band. Thirteen of the parcels had been
allotted to individual Indians under § 3; seven had been sold to
non-Indians as pine lands under § § 4 and 5 for commercial timber
harvest; and one parcel had been distributed to a non-Indian under
§ 6 as a homestead plot. Under protest and to avoid foreclosure,
the Leech Lake Band paid more than $64,000 in taxes, interest, and
penalties.
In 1995, the Band filed suit in federal court seeking a
declaratory judgment that Cass County could not tax the 21
parcels.1 The District Court granted summary judgment in favor of
Cass County, holding that all of the land that had been alienated
from tribal ownership under the Nelson Act was taxable. 908 F.
Supp. 689 (Minn. 1995). The District Court interpreted our decision
in
Yakima to mean that "if Congress has made Indian land
freely alienable, states may tax the land"-that is, "alienability
equals taxability." 908
A divided panel of the United States Court of Appeals for the
Eighth Circuit affirmed in part and reversed in part.
108 F.3d
820 (1997). Noting that
Yakima reaffirmed prior
statements by this Court indicating that Congress must make
"unmistakably clear" its intent to subject reservation lands to
state or local taxation, 108 F.3d, at 826, the panel
1 Also in 1995, the Band successfully applied, pursuant to § 465
of the Indian Reorganization Act, 25 U. S. C. § 465, to restore 11
of the parcels to federal trust status. See
infra, at
114-115; App. to Pet. for Cert. 56; Tr. of Oral Arg. 9.
110
majority held that the 13 parcels allotted to individual Indians
under § 3 of the Nelson Act could be taxed so long as the District
Court confirmed on remand that they had been patented after passage
of the Burke Act proviso, because the explicit mention of
"taxation" in the proviso manifested the necessary "unmistakably
clear" intent.
Id., at 827,829-830. But the panel majority
further held that the eight parcels sold as pine lands or homestead
land under §§ 4-6 of the Nelson Act could not be taxed because
those sections, "unlike § 3, did not incorporate the GAA or include
any mention of an intent to tax lands distributed under them which
might become reacquired by the Band in fee."
Id., at
829.
Judge Magill concurred with the majority on the taxability of
the 13 allotted parcels, but he dissented from the holding that the
remaining 8 parcels were not also taxable. In his view,
Yakima propounded "the clear rule ... that alienability
allows taxation." 108 F. 3d, at 831.
We granted certiorari, 522 U. S. 944 (1997), to decide whether
Cass County may impose its ad valorem property tax on the seven
parcels sold as pine lands and the one sold as a homestead to
non-Indians.2
II
State and local governments may not tax Indian reservation land
"'absent cession of jurisdiction or other federal statutes
permitting it.'"
County of Yakima v.
Confederated Tribes
and Bands of Yakima Nation, 502 U. S., at 258 (quoting
Mescalero Apache Tribe v.
Jones, 411 U. S. 145, 148
(1973)). We have consistently declined to find that Congress has
authorized such taxation unless it has "'made its intention to do
so unmistakably clear.'"
Yakima, supra, at 258 (quoting
Montana v.
Blackfeet Tribe, 471 U. S. 759, 765
(1985)). We have determined that Congress has manifested
2We denied the cross-petition for a writ of certiorari filed by
the Band, which sought review of the holding by the courts below
that the 13 parcels allotted to Indians under § 3 of the Nelson Act
are taxable.
111
such an intent when it has authorized reservation lands to be
allotted in fee to individual Indians, thus making the lands freely
alienable and withdrawing them from federal protection. This was
the case in both
Yakima and Goudy v. Meath,
203 U. S. 146 (1906), in
which this Court held that land, allotted and patented in fee to
individual Indians and thus rendered freely alienable after the
expiration of federal trust status, was subject to county ad
valorem taxes even though it was within a reservation and held by
either individual Indians or a tribe.
In Goudy, Congress had made reservation land alienable by
authorizing the President to issue patents to individual members of
the Puyallup Tribe. The President issued such a patent to the
plaintiff shortly before Washington became a State. The treaty of
March 16, 1854, between the United States and the Puyallup Tribe,
10 Stat. 1043, provided that such fee-patented land "shall be
exempt from levy, sale, or forfeiture" until a state constitution
was adopted and the state legislature removed the restrictions with
Congress' consent. When Washington became a State, its legislature
passed a law authorizing the sale of reservation lands; shortly
thereafter, Congress authorized the appointment of a commission
with the power to superintend the sale of those lands, with the
proviso that "the Indian allottees shall not have power of
alienation of the allotted lands not selected for sale by said
Commission for a period of ten years from the date of the passage
of this act." 27 Stat. 633 (1893).
When the 10-year period expired, the county levied an ad valorem
tax on the land. This Court held that the tax was permissible
because the land was freely alienable. Goudy v. Meath, 203 U. S.,
at 149-150. Although the Indian patent owner argued that there had
been no express repeal of the exemption provided by the 1854
treaty, this Court stated that such an express repeal was
unnecessary:
"That Congress may grant the power of voluntary sale, while
withholding the land from taxation or forced alien-
112
ation may be conceded .... But while Congress may make such
provision, its intent to do so should be clearly manifested."
Id, at 149.
The Goudy Court concluded that it would "seem strange [for
Congress] to withdraw [federal] protection and permit the Indian to
dispose of his lands as he pleases, while at the same time
releasing [the lands] from taxation."
Ibid. Indeed, because
such congressional purpose would be unreasonable, Congress would
have to "clearly manifest" such a contrary purpose in order to
counteract the consequence of taxability that ordinarily flows from
alienability.
Ibid.
In
Yakima, we considered whether the GAA manifested an
unmistakably clear intent to allow state and local taxation of
reservation lands allotted under the GAA and owned in fee by either
the Yakima Indian Nation or individual Indians.3 In holding that
the lands could be taxed, we noted that the Burke Act proviso
clearly manifested such an intent by expressly addressing the
taxability of fee-patented land. 502 U. S., at 259. We also
indicated that the alienability of allotted lands itself, as
provided by § 5 of the GAA, similarly manifested an unmistakably
clear intent to allow taxation.4 We reasoned that Goudy, "without
even mentioning the
3 We are concerned here only with
Yakima's holding with
respect to ad valorem taxes such as those at issue in this case.
Yakima also held that the GAA did not authorize the county
to impose an excise tax on the
sale of land held by
individual Indians or by the tribe, because such a tax did not
constitute the "taxation ofland." See
County of Yakima v.
Confederated Tribes and Bands of Yakima Nation, 502 U. S. 251, 268-269
(1992). That holding, however, is not relevant to this case, which
involves only an ad valorem tax on land itself, rather than an
excise tax on a transaction.
4 The Burke Act proviso, as noted, see
supra, at 107, did
not itself authorize taxation of fee-patented land; it merely
altered the result of
In re Heff, 197 U. S. 488 (1905), as
to when parcels allotted to the Indians could be alienated and
taxed.
In re Heffhad held this occurred as soon as allotted
lands were patented to the Indians in
trust (during which
the land would still be under the protection of the Federal
Government); the Burke Act proviso stated that this did not occur
until the lands were patented in
fee.
113
Burke Act proviso," 502 U. S., at 259, had held that state tax
laws applied to the Indian allottee at the expiration of the trust
period: "[I]t was the alienability of the allotted lands ... that
the
[Goudy] Court found of central significance."
I
d., at 263 (emphasis deleted). And we reiterated
Goudy's
point that, although it is
possible for Congress to render
reservation land alienable and still forbid States to tax it, this
unlikely arrangement would not be presumed unless Congress "clearly
manifested" such an intent. 502 U. S., at 263 (internal quotation
marks and citation omitted).
The Court of Appeals thus erred in concluding that our holding
in
Yakima turned on the Burke Act proviso's express
reference to taxability.
Yakima, like
Goudy, stands
for the proposition that when Congress makes reservation lands
freely alienable, it is "unmistakably clear" that Congress intends
that land to be taxable by state and local governments, unless a
contrary intent is "clearly manifested." 502 U. S., at 263.
The foregoing principle controls the disposition of this case.
In §§ 5 and 6 of the Nelson Act, Congress provided for the public
sale of pine lands and agricultural "homestead" lands by the
Federal Government to non-Indians. Congress thereby removed that
reservation land from federal protection and made it fully
alienable. Under
Goudy and
Yakima, therefore, it is
taxable. Indeed, this conclusion flows
a fortiori from
Goudy and
Yakima: Those cases establish that Congress
clearly intended reservation lands conveyed in fee to
Indians to be subject to taxation; hence Congress surely
intended reservation lands conveyed in fee to
non-Indians
also to be taxable. The Court of Appeals' contrary holding
attributes to Congress the odd intent that parcels conveyed to
Indians are to assume taxable status, while parcels sold to
the
general public are to remain tax exempt.
The Band essentially argues that, although its tax immunity lay
dormant during the period when the eight parcels were held by
non-Indians, its reacquisition of the lands in
114
fee rendered them nontaxable once again. We reject this
contention. As explained, once Congress has demonstrated (as it has
here) a clear intent to subject the land to taxation by making it
alienable, Congress must make an unmistakably clear statement in
order to render it nontaxable. See
County of Yakima v.
Confederated Tribes and Bands of Yakima Nation, 502 U. S.,
at 263 (citing
Goudy v.
Meath, supra, at 149). The
subsequent repurchase of reservation land by a tribe does not
manifest any congressional intent to reassume federal protection of
that land and to oust state taxing authority-particularly when
Congress explicitly relinquished such protection many years
before.
Further, if we were to accept the Leech Lake Band's argument, it
would render partially superfluous § 465 of the Indian
Reorganization Act. That section grants the Secretary of the
Interior authority to place land in trust, to be held by the
Federal Government for the benefit of the Indians and to be exempt
from state and local taxation after assuming such status:
"The Secretary of the Interior is authorized, in his discretion,
to acquire, through purchase, relinquishment, gift, exchange, or
assignment, and interest in lands ... within or without existing
reservations ... for the purpose of providing land for Indians
....
"Title to any lands ... shall be taken in the name of the United
States in trust for the Indian tribe or individual Indian for which
the land is acquired, and such lands ... shall be exempt from State
and local taxation." 25 U. S. C. § 465.
In § 465, therefore, Congress has explicitly set forth a
procedure by which lands held by Indian tribes may become tax
exempt. It would render this procedure unnecessary, as far as
exemption from taxation is concerned, if we held that taxexempt
status automatically attaches when a tribe acquires reservation
land. The Leech Lake Band apparently realizes
115
this, because in 1995 it successfully applied to the Secretary
of the Interior under § 465 to restore federal trust status to
seven of the eight parcels at issue here. See Complaint ~ 18 and
Affidavit of Joseph F. Halloran in support of Plaintiff's Motion
for Summary Judgment, in Civ. No. 5-95-99, ~ V (DC Minn.); Tr. of
Oral Arg. 9.5
***
When Congress makes Indian reservation land freely alienable, it
manifests an unmistakably clear intent to render such land subject
to state and local taxation. The repurchase of such land by an
Indian tribe does not cause the land to reassume tax-exempt status.
The eight parcels at issue here were therefore taxable unless and
until they were restored to federal trust protection under § 465.
The judgment of the Court of Appeals with respect to those lands is
reversed.
It is so ordered.
5 The Leech Lake Band and the United States, as
amicus,
also argue that the parcels at issue here are not alienable-and
therefore not taxable-under the terms of the Indian Nonintercourse
Act, which provides:
"No purchase, grant, lease, or other conveyance of lands ...
from any Indian nation or tribe ... shall be of any validity in law
or equity, unless the same be made by treaty or convention entered
into pursuant to the Constitution." 25 U. S. C. § 177.
This Court has never determined whether the Indian
Nonintercourse Act, which was enacted in 1834, applies to land that
has been rendered alienable by Congress and later reacquired by an
Indian tribe. Because the parcels at issue here are not
alienable-and therefore not taxableunder the terms of the Indian
Nonintercourse Act, which provides: "No taxation if it remains
freely alienable", and because it was not addressed by the Court of
Appeals, we decline to consider it for the first time in this
Court. See,
e. g., Matsushita Elec. Indus. Co. v.
Epstein, 516
U. S. 367, 379, n. 5 (1996) (declining to address issue both
because it was "outside the scope of the question presented in this
Court" and because "we generally do not address arguments that were
not the basis for the decision below").
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