--===Washington State Courts - Opinions===--
 

_Washington State Supreme Court
 Opinions: State of Washington vs. Donald Ray Buchanan _

                                                                               
                                                                   
                    Supreme Court of the State of Washington                   
                                                                      
                                                                               
                                                                      
                            Opinion Information Sheet                          
                                                                      
                                                                               
                                                                      
Docket Number:       66054-9                                                   
                                                                      
Title of Case:       State of Washington                                       
                                                                      
                     v.                                                        
                                                                      
                     Donald Ray Buchanan                                       
                                                                      
File Date:           06/17/1999                                                
                                                                      
Oral Argument Date:  11/18/1998                                                
                                                                      
                                                                               
                                                                      
                                                                               
                                                                      
                                SOURCE OF APPEAL                               
                                                                      
                                ----------------                               
                                                                      
Appeal from Superior Court,                                                    
                                                                      
            Yakima County;                                                     
                                                                      
            95-1-00124-1                                                       
                                                                      
            Honorable Heather Van Nuys, Judge.                                 
                                                                      
                                                                               
                                                                      
                                                                               
                                                                      
                                    JUSTICES                                   
                                                                      
                                    --------                                   
                                                                      
Authored by Richard P. Guy                                                     
                                                                      
Concurring: Barbara Durham                                                     
                                                                      
            Charles Z. Smith                                                   
                                                                      
            Charles W. Johnson                                                 
                                                                      
            Barbara A. Madsen                                                  
                                                                      
            Gerry L. Alexander                                                 
                                                                      
            Philip A. Talmadge                                                 
                                                                      
            Richard B. Sanders                                                 
                                                                      
            Visiting Judge                                                     
                                                                      
                                                                               
                                                                      
                                                                               
                                                                      
                                COUNSEL OF RECORD                              
                                                                      
                                -----------------                              
                                                                      
Counsel for Petitioner(s)                                                      
                                                                      
            Jeffrey C. Sullivan                                                
                                                                      
            Prosecuting Attorney                                               
                                                                      
            Pros Atty Offc Rm 329                                              
                                                                      
            128 N 2nd St                                                       
                                                                      
            Yakima, WA  98901-2614                                             
                                                                      
                                                                               
                                                                      
            Kenneth L. Ramm Jr.                                                
                                                                      
            Deputy Prosecutor                                                  
                                                                      
            Yakima County Courthouse                                           
                                                                      
            128 N 2nd St  Rm 329                                               
                                                                      
            Yakima, WA  98901-2631                                             
                                                                      
                                                                               
                                                                      
            Lauri M. Boyd                                                      
                                                                      
            Yakima Co Crths-Appel Div                                          
                                                                      
            128 N 2nd St Ste 211                                               
                                                                      
            Yakima, WA  98901-2631                                             
                                                                      
                                                                               
                                                                      
Counsel for Respondent(s)                                                      
                                                                      
            David S. Vogel                                                     
                                                                      
            Law Offices of David S. Vogel                                      
                                                                      
            520 Pike St #1505                                                  
                                                                      
            Seattle, WA  98101-4044                                            
                                                                      
                                                                               
                                                                      
Amicus Curiae on behalf of Wa State Departmentof Fish & Wildli                 
                                                                      
            Robert K. Costello                                                 
                                                                      
            Assistant Attorney General                                         
                                                                      
            1125 Washington St SE                                              
                                                                      
            PO Box 40100                                                       
                                                                      
            Olympia, WA  98504-0100                                            
                                                                      
                                                                               
                                                                      
Amicus Curiae on behalf of Modern Firearm Hunters of Washington                
                                                                      
            Joseph L. Coniff Jr.                                               
                                                                      
            Attorney At Law                                                    
                                                                      
            2120 State Ave NE Ste 201                                          
                                                                      
            Olympia, WA  98506-4762                                            
                                                                      
                                                                               
                                                                      
Amicus Curiae on behalf of Ralph W Professo Johnson                            
                                                                      
            Ralph W. Johnson                                                   
                                                                      
            Univ of Wa Law School                                              
                                                                      
            1100 NE Campus Pky #jb20                                           
                                                                      
            Seattle, WA  98105-6605                                            
                                                                      
                                                                               
                                                                      
Amicus Curiae on behalf of Squaxin Island Tribe                                
                                                                      
            Kevin R. Lyon                                                      
                                                                      
            Attorney At Law                                                    
                                                                      
            112 4th Ave E Ste 200                                              
                                                                      
            Olympia, WA  98501-1103                                            
                                                                      
                                                                               
                                                                      
            Ronald J. Whitener                                                 
                                                                      
            Squaxin Island Legal Dept                                          
                                                                      
            112 E 4th Ave Ste 200                                              
                                                                      
            Olympia, WA  98501                                                 
                                                                      
                                                                               
                                                                      
Amicus Curiae on behalf of Tulalip Tribes                                      
                                                                      
            Mason D. Morisset                                                  
                                                                      
            Morisset Schlosser Ayer...                                         
                                                                      
            1115 Norton Bulding                                                
                                                                      
            801 Second Avenue                                                  
                                                                      
            Seattle, WA  98104-1509                                            
                                                                      
                                                                               
                                                                      
Amicus Curiae on behalf of Nisqually Indian Tribe                              
                                                                      
            Bill Tobin                                                         
                                                                      
            Attorney At Law                                                    
                                                                      
            P.O. Box 1425                                                      
                                                                      
            Vashon, WA  98070-1425                                             
                                                                      
                                                                               
                                                                      
Amicus Curiae on behalf of Sauk-Suiattle Tribe                                 
                                                                      
            Allen H. Sanders                                                   
                                                                      
            907 37th Ave                                                       
                                                                      
            Seattle, WA  98122-5226                                            
                                                                      
                                                                               
                                                                      
            Phillip E. Katzen                                                  
                                                                      
            Columbia Legal Services                                            
                                                                      
            101 Yesler, Suite 301                                              
                                                                      
            Seattle, WA  98104                                                 
                                                                      
                                                                               
                                                                      
Amicus Curiae on behalf of Skokomish Tribe                                     
                                                                      
            Kathryn J. Nelson                                                  
                                                                      
            Eisenhower Carlson Newlands Reha Henriot & Quinn                   
                                                                      
            1200 1st Interstate Plaza                                          
                                                                      
            1201 Pacific Ave                                                   
                                                                      
            Tacoma, WA  98402                                                  
                                                                      
                                                                               
                                                                      
Amicus Curiae on behalf of Puyallup Tribe                                      
                                                                      
            Debra S. O'Gara                                                    
                                                                      
            Puyallup Indian Tribe                                              
                                                                      
            2002 E 28th St                                                     
                                                                      
            Tacoma, WA  98404-6110                                             
                                                                      
                                                                               
                                                                      
Amicus Curiae on behalf of Upper Skagit Tribe                                  
                                                                      
            Harold Chesnin                                                     
                                                                      
            Mathews Garlington-Mathews & Chesnin                               
                                                                      
            219 S Washington Street                                            
                                                                      
            Seattle, WA  98104-2600                                            
                                                                      
                                                                               
                                                                      
Amicus Curiae on behalf of Lummi Tribe                                         
                                                                      
            Daniel A. Raas                                                     
                                                                      
            Raas Johnsen & Stuen                                               
                                                                      
            1503 E St.                                                         
                                                                      
            Bellingham, WA  98225-3007                                         
                                                                      
                                                                               
                                                                      
Amicus Curiae on behalf of Swinomish Indian Tribal Community                   
                                                                      
            Alix Foster                                                        
                                                                      
            Office of Tribal Atty                                              
                                                                      
            PO Box 817                                                         
                                                                      
            La Conner, WA  98257-0817                                          
                                                                      
                                                                               
                                                                      
            Allan E. Olson                                                     
                                                                      
            P.O. Box 817                                                       
                                                                      
            La Conner, WA  98257                                               
                                                                      
                                                                               
                                                                      
Amicus Curiae on behalf of Suquamish Tribe                                     
                                                                      
            John C. Sledd                                                      
                                                                      
            8002 Illahee Rd NE                                                 
                                                                      
            Bremerton, WA  98311                                               
                                                                      
                                                                               
                                                                      
Amicus Curiae on behalf of Bands of Yakama Indian Nation                       
                                                                      
            Elizabeth F. Nason                                                 
                                                                      
            Yakima Indian Nation                                               
                                                                      
            P.O. Box 151                                                       
                                                                      
            Toppenish, WA  98948                                               
                                                                      
                                                                               
                                                                      
Amicus Curiae on behalf of Nooksack Tribe                                      
                                                                      
            Jeffrey J. Bode                                                    
                                                                      
            Attorney At Law                                                    
                                                                      
            P.O. Box 6092                                                      
                                                                      
            Bellingham, WA  98227                                              
                                                                      
                                                                               
                                                                      
Amicus Curiae on behalf of Muckleshoot Indian Tribe                            
                                                                      
            Alan C. Stay                                                       
                                                                      
            Muckleshoot Indian Tribe                                           
                                                                      
            39015 - 172nd Ave SE                                               
                                                                      
            Auburn, WA  98092                                                  
                                                                      
                                                                               
                                                                      
            Robert L. Otsea Jr.                                                
                                                                      
            1527 Lk Washington Blvd S                                          
                                                                      
            Seattle, WA  98144                                                 
                                                                      
                                                                               
                                                                      
                                                                               
                                                                      
                                                                               
                                                                      
IN THE SUPREME COURT OF THE STATE OF WASHINGTON                                
                                                                      
                                                                               
                                                                      
STATE OF WASHINGTON,                             )                             
                                                                      
                                                 )                             
                                                                      
 Appellant,                                      ) No. 66054-9                 
                                                                      
                                                 )                             
                                                                      
v.                                               )                             
                                                                      
                                                 ) EN BANC                     
                                                                      
DONALD RAY BUCHANAN,                             )                             
                                                                      
                                                 )                             
                                                                      
                                  Respondent.    ) Filed June 17, 1999.        
                                                                      
                                                                               
                                                                      
GUY, C.J.  This is a criminal prosecution for illegal hunting of elk in the    
                                                                      
State-owned Oak Creek Wildlife Area.  The defendant, a member of the           
                                                                      
Nooksack Indian Tribe, claims he has a treaty right to hunt elk in the Oak     
                                                                      
Creek Area, and that this right may not be restricted by state hunting         
                                                                      
regulations.  The issues presented are (1) whether the geographic scope of     
                                                                      
the tribe's treaty right to hunt on open and unclaimed lands includes the      
                                                                      
Oak Creek Wildlife Area, (2) whether the Oak Creek Wildlife Area is open       
                                                                      
and unclaimed land, and (3)                                                    
                                                                      
whether the tribe's treaty right to hunt outside the reservation was           
                                                                      
abrogated by Washington's admission to the Union "on equal footing" with       
                                                                      
the original states.                                                           
                                                                      
We reverse the dismissal of the criminal action and remand for trial.  We      
                                                                      
hold that, on remand, the defendant may raise a treaty right to hunt as a      
                                                                      
defense to the criminal charges and may offer evidence in support of his       
                                                                      
position that the Oak Creek Wildlife Area is within the aboriginal hunting     
                                                                      
grounds of the Nooksack Tribe.  We also hold that under the facts presented    
                                                                      
in this case, the Oak Creek Wildlife Area is "open and unclaimed" land         
                                                                      
within the meaning of the Nooksack's treaty.  We decline, in this case, to     
                                                                      
reconsider prior case law on whether the equal footing doctrine applies to     
                                                                      
impliedly abrogate Indian treaty rights in Washington.                         
                                                                      
FACTS                                                                          
                                                                      
     On January 6, 1995, defendant Donald Buchanan was stopped by              
                                                                      
Department of Fish and Wildlife enforcement officers while Buchanan was        
                                                                      
hunting in the Oak Creek Wildlife Area, land which is owned and managed by     
                                                                      
the State of Washington.  The defendant was in possession of two recently      
                                                                      
killed five-point, branch-antlered bull elks.  At the time he was stopped,     
                                                                      
the defendant's Washington state hunting license had been revoked, and the     
                                                                      
Washington elk hunting season was closed.                                      
                                                                      
     The Oak Creek Wildlife Area, which is near Yakima, is open to the         
                                                                      
public at specified times each year for hunting, fishing and recreational      
                                                                      
purposes.   During the fall and winter of 1994-95, state regulations           
                                                                      
permitted elk hunting in the Oak Creek Wildlife Area only from November 5      
                                                                      
through 13, 1994.  The number of branch-antlered elk that could be killed      
                                                                      
also was regulated during the hunting season, and only young "spike bulls"     
                                                                      
could be killed without a special permit.  The purposes of the restrictions    
                                                                      
on elk hunting in the Oak Creek Wildlife Area are to maintain and manage       
                                                                      
the existing elk population.  However, there is not an immediate threat to     
                                                                      
elk, as a species, in the Oak Creek Wildlife Area.                             
                                                                      
     Defendant Buchanan is a resident of Kent, Washington, and a member of     
                                                                      
the Nooksack Indian Tribe.  At the time he was stopped by Wildlife             
                                                                      
enforcement officers, he possessed both a Nooksack Tribe identification        
                                                                      
card and hunting tags issued by the Tribe.  The Nooksack Tribe's               
                                                                      
reservation is located in Whatcom County, near Deming.  The lands ceded to     
                                                                      
the United States by the Nooksack Tribe under the provisions of the Treaty     
                                                                      
of Point Elliott,1 which is the treaty involved here, are bordered on the      
                                                                      
east by the summit of the Cascade range.  The Oak Creek Wildlife Area is       
                                                                      
east of the territory ceded to the United States by the Nooksacks.             
                                                                      
     Defendant Buchanan was charged with two felony counts of possessing       
                                                                      
big game during a closed season, former RCW 77.16.020(1)(E), former RCW        
                                                                      
77.21.010(1) (second or subsequent violation), and with one misdemeanor        
                                                                      
count of hunting while license is revoked.  Former RCW 77.21.060(2).2          
                                                                      
     Defendant Buchanan moved to dismiss the charges on the ground that        
                                                                      
State hunting regulations do not apply to hunters, like Buchanan, who are      
                                                                      
members of Indian tribes that have a treaty right to hunt on open and          
                                                                      
unclaimed lands.  He claims the only regulations that govern his hunting on    
                                                                      
open and unclaimed lands are those of the Nooksack Indian Tribe.               
                                                                      
     The trial court granted the motion to dismiss the charges, ruling:        
                                                                      
(1) the language of the Treaty of Point Elliott does not restrict hunting      
                                                                      
to open and unclaimed lands within the area ceded by the Indians to the        
                                                                      
United States, but instead gives tribal members a right to hunt anywhere in    
                                                                      
the "Territory of Washington"; (2) the term "open and unclaimed lands"         
                                                                      
includes public lands, such as the Oak Creek Wildlife Area, which are put      
                                                                      
to uses compatible with an Indian hunting privilege; and (3) although          
                                                                      
Indian hunting privileges may be limited if necessary for conservation, the    
                                                                      
State, in this case, failed to                                                 
                                                                      
demonstrate that application of State hunting regulations to treaty tribe      
                                                                      
hunters is necessary for conservation.                                         
                                                                      
     On appeal, the State challenged the trial court's conclusions and,        
                                                                      
additionally, argued that the Treaty of Point Elliott was abrogated by         
                                                                      
Congress when Washington was admitted to the Union on equal footing with       
                                                                      
the original states.  The Court of Appeals affirmed and declined to            
                                                                      
consider the equal footing argument, as that issue was not presented to the    
                                                                      
trial court and was not asserted to be of constitutional magnitude.  State     
                                                                      
v. Buchanan, 87 Wn. App. 189, 196, 941 P.2d 683 (1997), review granted, 134    
                                                                      
Wn.2d 1012 (1998).  This court granted the State's petition for review.        
                                                                      
Several treaty tribes, including the Nooksack Tribe, have filed an amicus      
                                                                      
brief providing an overview of tribal management of off-reservation hunting    
                                                                      
by tribal members, a description of cooperative agreements governing           
                                                                      
wildlife management between tribes and between various tribes and the          
                                                                      
State, and further setting forth the tribes' position on the meaning of        
                                                                      
"open and unclaimed" lands.3   Professor Ralph Johnson of the University of    
                                                                      
Washington School of Law has filed an amicus brief on the proper               
                                                                      
interpretation of the treaty language "open and unclaimed" lands.  An          
                                                                      
amicus brief has been filed by the Department of Fish and Wildlife on the      
                                                                      
issues of the geographical scope of the treaty right involved and on the       
                                                                      
designation of the Oak Creek Wildlife Area as open and unclaimed lands         
                                                                      
during the winter months.  Modern Firearm Hunters of Washington has filed      
                                                                      
an amicus brief in support of the State's equal footing argument.              
                                                                      
     Prior to oral argument in this court, the State filed a motion            
                                                                      
captioned, "Request for Judicial Notice or to Supplement the Record Under      
                                                                      
RAP 9.11."  In its motion the State argues that defendant Buchanan should      
                                                                      
not be permitted to raise the defense that he has a treaty right to hunt       
                                                                      
because the Nooksack Tribe was not a signatory to the Treaty of Point          
                                                                      
Elliott.  Defendant Buchanan responded to the motion and, additionally,        
                                                                      
moved for sanctions against the State, arguing the motion was frivolous and    
                                                                      
made for purposes of delay.  Both motions were passed to the merits.           
                                                                      
ISSUES                                                                         
                                                                      
     1.  What is the geographic scope of the Nooksack Indian Tribe's treaty    
                                                                      
hunting right?                                                                 
                                                                      
     2.  Is the State-owned Oak Creek Wildlife Area "open and unclaimed        
                                                                      
lands" within the meaning of the Treaty of Point Elliott?                      
                                                                      
     3.  Were those provisions of the Treaty of Point Elliott which            
                                                                      
conflict with the State's right to regulate off-reservation hunting            
                                                                      
abrogated by Congress when Washington was admitted to the Union upon "equal    
                                                                      
footing" with the original states?                                             
                                                                      
DISCUSSION                                                                     
                                                                      
We begin by denying both the State's motion for judicial notice or to          
                                                                      
supplement the record and the defendant's motion for sanctions.                
                                                                      
In its motion, the State first argues that this court should take judicial     
                                                                      
notice that the court lacks "subject matter jurisdiction" over defendant       
                                                                      
Buchanan's defense because the Nooksack Tribe was not a signatory to the       
                                                                      
Treaty of Point Elliott and Buchanan, therefore, has no treaty hunting         
                                                                      
rights.                                                                        
                                                                      
     The State's motion raises a new issue that is, whether defendant          
                                                                      
Buchanan failed to prove a necessary element (the existence of a treaty) of    
                                                                      
his defense.  The court generally will not consider issues which are not       
                                                                      
set forth in the petition for review, RAP 13.7(b), nor arguments raised for    
                                                                      
the first time on appeal.  See, e.g., Hansen v. Friend, 118 Wn.2d 476, 485,    
                                                                      
824 P.2d 483 (1992).  However, this rule does not apply when the issue         
                                                                      
raised affects the right to maintain an action.  Jones v. Stebbins, 122        
                                                                      
Wn.2d 471, 479, 860 P.2d 1009 (1993).  In this case, the State claims that     
                                                                      
defendant Buchanan does not have a right to maintain his defense and,          
                                                                      
therefore, the court should take judicial notice that it is without            
                                                                      
jurisdiction to consider it.                                                   
                                                                      
     The issue raised by the State does not present a jurisdictional           
                                                                      
question.  Jurisdiction is the power of the court to hear and determine the    
                                                                      
class of action to which a case belongs.  State v. Werner, 129 Wn.2d 485,      
                                                                      
493, 918 P.2d 916 (1996); Bour v. Johnson, 80 Wn. App. 643, 647, 910 P.2d      
                                                                      
548 (1996).  This is a criminal felony action brought by the State.  The       
                                                                      
trial court had authority to determine the legal and factual issues            
                                                                      
involved.  RCW 2.08.010; Werner, 129 Wn.2d at 493.  This court has the         
                                                                      
power to determine the appeal.  RCW 2.04.010.                                  
                                                                      
Alternatively, the State asks to supplement the record with documents          
                                                                      
showing that the Nooksack Indian Tribe has previously taken the position       
                                                                      
that it was not a party to the treaty.  This issue was resolved in 1978 in     
                                                                      
an action in which the State of Washington was a defendant, and in which       
                                                                      
the trial court ruled that the Nooksack Indian Tribe was included in the       
                                                                      
Treaty of Point Elliott.  United States v. Washington, 459 F. Supp. 1020,      
                                                                      
1040-41 (W.D. Wash. 1978) (posttrial substantive orders following the          
                                                                      
initial Boldt decision4), aff'd, 645 F.2d 749 (9th Cir. 1981) (the appeal      
                                                                      
does not challenge the trial court's ruling relating to the Nooksack's         
                                                                      
status as a treaty tribe).                                                     
                                                                      
     The State argues that this court need not consider the federal court      
                                                                      
decision because it is "a lower federal court case which is non-binding        
                                                                      
precedent on this court."  Request for Judicial Notice at 6.  However, the     
                                                                      
State was a party to the federal court case and is bound by its ruling.        
                                                                      
Puget Sound Gillnetters Ass'n v. Moos, 92 Wn.2d 939, 953, 603 P.2d 819         
                                                                      
(1979) (all parties, and all those who are in privity with parties, must       
                                                                      
comply with the federal court orders entered in United States v.               
                                                                      
Washington). See also Nielson v. Spanaway Gen. Med. Clinic, Inc., 135 Wn.2d    
                                                                      
255, 262, 956 P.2d 312 (1998) (the doctrine of collateral estoppel prevents    
                                                                      
relitigation of an issue, in state court, after the party against whom the     
                                                                      
doctrine is applied has had a full and fair opportunity to litigate his or     
                                                                      
her case in federal court).  The State claims the federal trial court's        
                                                                      
decision on the issue is erroneous, but it did not appeal the trial court's    
                                                                      
findings and conclusion with respect to the Nooksack Tribe.  Recourse from     
                                                                      
an erroneous federal court decision is through the federal system.  Puget      
                                                                      
Sound Gillnetters, 92 Wn.2d at 952.  Accordingly, we deny the motion to        
                                                                      
supplement.                                                                    
                                                                      
     Although we deny the State's motion, we decline to impose sanctions       
                                                                      
against it.  We are satisfied that the motion was filed in good faith.         
                                                                      
     We turn now to the substantive issues in this appeal.                     
                                                                      
     Defendant Buchanan's defense to the criminal charges brought against      
                                                                      
him is that he is not subject to State hunting laws because he has a treaty    
                                                                      
right to hunt on any open and unclaimed lands in "Washington Territory,"       
                                                                      
and that this treaty right is superior to the right of the State to            
                                                                      
regulate hunting.                                                              
                                                                      
     The State makes essentially three arguments.  First, it argues that       
                                                                      
any treaty hunting right that exists in the Nooksack Tribe should be           
                                                                      
interpreted to permit hunting only on open and unclaimed land within the       
                                                                      
area ceded to the United States by the tribe, or upon land which the tribe     
                                                                      
has traditionally hunted.  Second, the State argues that even if the treaty    
                                                                      
affords a right to hunt outside the ceded area, the Oak Creek Wildlife Area    
                                                                      
is not "open and unclaimed" land.  Finally, it urges this court to hold        
                                                                      
that no treaty right to hunt or fish in violation of State regulations         
                                                                      
survived Washington's admission to the Union on "equal footing" with the       
                                                                      
original states.                                                               
                                                                      
     Our initial inquiry is to determine the geographic scope of the           
                                                                      
Nooksack Tribe's treaty hunting right.                                         
                                                                      
     In 1854 and 1855 Isaac Stevens, who was the first Governor and            
                                                                      
Superintendent of Indian Affairs for Washington Territory, negotiated          
                                                                      
several treaties between the United States and the various tribes and bands    
                                                                      
of Indians who lived in the Territory.5  See generally United States v.        
                                                                      
Washington, 384 F. Supp. 312, 353-57 (W.D. Wash. 1974); Seufert Bros. Co.      
                                                                      
v. United States, 249 U.S. 194, 39 S. Ct. 203, 63 L. Ed. 555 (1919).           
                                                                      
     At the time the treaties were negotiated, approximately three-fourths     
                                                                      
of Western Washington's 10,000 or so inhabitants were Indians.  Washington     
                                                                      
v. Washington State Commercial Passenger Fishing Vessel Ass'n, 443 U.S.        
                                                                      
658, 664, 99 S. Ct. 3055, 61 L. Ed. 2d 823 (1979) (hereafter Fishing           
                                                                      
Vessel).  The natural resources appeared to the parties to be                  
                                                                      
inexhaustible.  Fishing Vessel, 443 U.S. at 669.                               
                                                                      
     In the treaties, the Indians relinquished their interest in most of       
                                                                      
the Territory in exchange for monetary payments.  Additionally, certain        
                                                                      
relatively small parcels of land were reserved for the exclusive use of        
                                                                      
particular tribes or bands, and the Indians were afforded other guarantees,    
                                                                      
such as certain rights of fishing and hunting.  Fishing Vessel, 443 U.S. at    
                                                                      
662.                                                                           
                                                                      
     The Treaty of Point Elliott was made in January 1855 and ratified         
                                                                      
March 8, 1859.  As noted above, the Nooksack Indian Tribe was judicially       
                                                                      
determined to be a party to the treaty in United States v. Washington, 459     
                                                                      
F. Supp. 1020.  The first article of the treaty includes a description of      
                                                                      
lands ceded to the United States by the Indians.  The treaty provides, in      
                                                                      
article 1, that the "said tribes and bands of Indians hereby cede,             
                                                                      
relinquish, and convey to the United States all their right, title, and        
                                                                      
interest in and to the lands and country occupied by them, bounded and         
                                                                      
described as follows:  Commencing at {the inlets and bays of western           
                                                                      
Washington Territory} to the summit of the Cascade range of mountains."        
                                                                      
Treaty of Point Elliott at 927.                                                
                                                                      
     Article 5 of the treaty provides:                                         
                                                                      
     The right of taking fish at usual and accustomed grounds and stations     
                                                                      
is further secured to said Indians in common with all citizens of the          
                                                                      
Territory, and of erecting temporary houses for the purpose of curing,         
                                                                      
together with the privilege of hunting and gathering roots and berries on      
                                                                      
open and unclaimed lands.  Provided, however, that they shall not take         
                                                                      
shell-fish from any beds staked or cultivated by citizens.                     
                                                                      
Treaty of Point Elliott at 928.                                                
                                                                      
     This paragraph was substantially the same in all of the Stevens           
                                                                      
Treaties,6 and its language has been the subject of extensive litigation in    
                                                                      
both state and federal court during much of the last century.  See, e.g.,      
                                                                      
United States v. Winans, 198 U.S. 371, 25 S. Ct. 662, 49 L. Ed 1089 (1905);    
                                                                      
Seufert Bros., 249 U.S. 194; Tulee v. Washington, 315 U.S. 681, 62 S. Ct.      
                                                                      
862, 86 L. Ed. 1115 (1942); State v. Towessnute, 89 Wash. 478, 154 P. 805      
                                                                      
(1916); State v. Wallahee, 143 Wash. 117, 255 P. 94 (1927); State v. McCoy,    
                                                                      
63 Wn.2d 421, 387 P.2d 942 (1963); State v. Chambers, 81 Wn.2d 929, 506        
                                                                      
P.2d 311 (1973); State v. Petit, 88 Wn.2d 267, 558 P.2d 796 (1977); State      
                                                                      
v. Miller, 102 Wn.2d 678, 689 P.2d 81 (1984); Atwood v. Shanks, 91 Wn. App.    
                                                                      
404, 958 P.2d 332 (1998); United States v. Alaska Packers' Ass'n, 79 F. 152    
                                                                      
(N.D. Wash. 1897); United States v. Hicks, 587 F. Supp. 1162 (W.D. Wash.       
                                                                      
1984); United States v. Washington, 384 F. Supp. 312; United States v.         
                                                                      
Washington, 157 F.3d 630 (9th Cir. 1998); State v. Arthur, 74 Idaho 251,       
                                                                      
261 P.2d 135 (1953).  See also Wilkinson, supra, at  447-48; Dana Johnson,     
                                                                      
Native American Treaty Rights to Scarce Natural Resources, 43 U.C.L.A. L.      
                                                                      
Rev. 547, 552 (1995); Bradley I. Nye, Where Do the Buffalo Roam?               
                                                                      
Determining the Scope of American Indian Off-Reservation Hunting Rights in     
                                                                      
the Pacific Northwest, 67 Wash. L. Rev. 175 (1992); Laurie Reynolds, Indian    
                                                                      
Hunting and Fishing Rights: The Role of Tribal Sovereignty and Preemption,     
                                                                      
62 N.C. L. Rev. 743 (1984).                                                    
                                                                      
     These authorities and others provide a framework for judicial             
                                                                      
examination of the treaty language involved here.                              
                                                                      
     Like any treaty between the United States and another sovereign           
                                                                      
nation, a treaty with Indians is the supreme law of the land and is binding    
                                                                      
on the State until Congress limits or abrogates the treaty.  U.S. Const.       
                                                                      
art. VI; Antoine v. Washington, 420 U.S. 194, 201, 95 S. Ct. 944, 43 L. Ed.    
                                                                      
2d 129 (1975); State v. McCormack, 117 Wn.2d 141, 143, 812 P.2d 483 (1991).    
                                                                      
     A treaty, including one between the United States and an Indian tribe,    
                                                                      
is essentially a contract between two sovereigns.  Fishing Vessel, 443 U.S.    
                                                                      
at 675; State v. Courville, 36 Wn. App. 615, 619, 676 P.2d 1011 (1983).        
                                                                      
When the signatory nations are not at war and neither is the vanquished, it    
                                                                      
is reasonable to assume the parties bargained at arm's length.  Fishing        
                                                                      
Vessel, 443 U.S. 675.  In discussing the negotiations involved in another      
                                                                      
Stevens Treaty, that with the Nez Perce, Professor Wilkinson states:           
                                                                      
{T}he stereotype of Indian leaders at treaty talks as being passive and        
                                                                      
overmatched intellectually is wrong.                                           
                                                                      
     The negotiators for the Nez Perce, and for the other tribes as well,      
                                                                      
had a complete understanding of the situation.  The white people wanted        
                                                                      
their land, and had the population and technology to take it.  The tribes,     
                                                                      
on the other hand, had considerable leverage: in time they would lose a        
                                                                      
military campaign, but they could exact great costs in terms of human life     
                                                                      
and monetary expenditures to fight a war on the fragile, far edge of           
                                                                      
American territory.                                                            
                                                                      
     The calculus was about power, and the tribes could make the               
                                                                      
calculations as well as the white people.  The tribal negotiators were         
                                                                      
sophisticated and they used every technique and device available to them.      
                                                                      
. . .  They made their arguments precisely and ably.                           
                                                                      
                                                                               
                                                                      
Wilkinson, supra, at 438 (footnotes omitted).                                  
                                                                      
     The goal of treaty interpretation is the same as the goal of contract     
                                                                      
interpretation to determine the intent of the parties.  Fishing Vessel, 443    
                                                                      
U.S. 675; United States v. Washington, 157 F.3d at 642.  The analysis of       
                                                                      
the parties' intention begins with the language of the treaty and the          
                                                                      
context in which the written words are used.  United States v. Washington,     
                                                                      
157 F.3d at 642.  In interpreting a treaty between the United States and an    
                                                                      
Indian tribe, the treaty must  "'be construed, not according to the            
                                                                      
technical meaning of its words to learned lawyers, but in the sense in         
                                                                      
which they would naturally be understood by the Indians.'"  Fishing Vessel,    
                                                                      
443 U.S. 676 (quoting Jones v. Meehan, 175 U.S. 1, 11, 20 S. Ct. 1, 5, 44      
                                                                      
L. Ed. 49 (1899)); Miller, 102 Wn.2d at 683.                                   
                                                                      
     Where there is ambiguity in the language of a treaty, it must not be      
                                                                      
construed to the prejudice of the Indians.  Minnesota v. Mille Lacs Band of    
                                                                      
Chippewa Indians, No. 97-1337, 1999 WL 155689 (U.S. Mar. 24, 1999);            
                                                                      
Antoine, 420 U.S. at 199; Miller, 102 Wn.2d at 683.  However, courts may       
                                                                      
not ignore treaty language that, viewed in its historical context and given    
                                                                      
a fair appraisal, clearly runs counter to the tribe's claims.  Oregon Dep't    
                                                                      
of Fish & Wildlife v. Klamath Indian Tribe, 473 U.S. 753, 774, 105 S. Ct.      
                                                                      
3420, 87 L. Ed. 2d 542 (1985); Department of Ecology v. Yakima Reservation     
                                                                      
Irrigation Dist., 121 Wn.2d 257, 277, 850 P.2d 1306 (1993).  Additionally,     
                                                                      
treaties must be construed liberally in favor of Indians.  Ecology, 121        
                                                                      
Wn.2d at 277; State v. Price, 87 Wn. App. 424, 429, 942 P.2d 377 (1997).       
                                                                      
     A key principle of treaty interpretation is known as the "reservation     
                                                                      
of rights doctrine."  First announced in United States v. Winans, 198 U.S.     
                                                                      
371, a case involving interpretation of a Stevens Treaty made with the         
                                                                      
Yakama Indians,7  the reservation of rights doctrine holds that a treaty       
                                                                      
between the federal government and an Indian tribe is not a grant of rights    
                                                                      
to the Indians but, rather, a grant from them.  In other words, the Indians    
                                                                      
ceded certain rights possessed by them at the time of making the treaty but    
                                                                      
reserved whatever rights were not expressly granted to the United States.      
                                                                      
Winans, 198 U.S. at 381.  See also Seufert Bros., 249 U.S. at 199; Fishing     
                                                                      
Vessel, 443 U.S. at 679-81; Wilkerson, supra, at 454-55.                       
                                                                      
     Under the reservation of rights doctrine, tribal members have             
                                                                      
possessed certain rights, such as hunting and fishing rights, from time        
                                                                      
immemorial.  A treaty between a tribe and the United States documents a        
                                                                      
grant of some rights from the tribe to the federal government.  However,       
                                                                      
those rights not expressly ceded in the treaty, as well as those expressly     
                                                                      
reserved, remain with the tribe.  Johnson, supra, at 553.                      
                                                                      
     The reservation of rights doctrine has consistently been applied to       
                                                                      
the fishing and hunting provisions of the Stevens Treaties.  See, e.g.,        
                                                                      
Fishing Vessel, 443 U.S. at 679-81; Seufert Bros., 249 U.S. at 196.            
                                                                      
The treaty language at issue here is the following:                            
                                                                      
     The right of taking fish at usual and accustomed grounds and stations     
                                                                      
is further secured to said Indians . . . together with the privilege of        
                                                                      
hunting . . . on open and unclaimed lands.                                     
                                                                      
                                                                               
                                                                      
     This court has interpreted the words "privilege" and "right," as used     
                                                                      
in the treaty, to be synonymous.  Miller, 102 Wn.2d at 683.  The United        
                                                                      
States Supreme Court has interpreted the treaty language "securing" or         
                                                                      
"secured" rights to be synonymous with "reserving" rights previously           
                                                                      
exercised.  Fishing Vessel, 443 U.S. at 678.                                   
                                                                      
     The State argues that the hunting right reserved by the treaty was        
                                                                      
limited to the right previously exercised that is to the ceded lands or to     
                                                                      
lands upon which the Nooksack Tribe traditionally hunted.  We agree.           
                                                                      
     The scope of a tribe's off-reservation hunting rights is generally        
                                                                      
found in an Indian tribe's aboriginal use of or title to land and its          
                                                                      
reservation of the right in a treaty, or by agreement, executive order or      
                                                                      
statute.  See generally Felix S. Cohen's Handbook of Federal Indian Law        
                                                                      
441-46 (Rennard Strickland & Charles F. Wilkinson eds., 1982).  Mr. Nye        
                                                                      
explains the origin of the right as follows:                                   
                                                                      
     Though hunting rights can arise from various sources, most existing       
                                                                      
off-reservation hunting rights in the Pacific Northwest were reserved by       
                                                                      
tribes in treaties signed with the federal government between 1853 and         
                                                                      
1871.  Treaties were the primary means by which the federal government         
                                                                      
sought to provide for the orderly westward expansion of non-native society.    
                                                                      
In the typical treaty, the signatory Indians relinquished their rights to      
                                                                      
aboriginal lands in exchange for money and confinement to a reservation        
                                                                      
with distinct boundaries.                                                      
                                                                      
     The reservation system, in addition to minimizing confrontations          
                                                                      
between encroaching settlers and the resident Indians, was also intended to    
                                                                      
transform Indians into "a pastoral and civilized people."  As a result,        
                                                                      
game populations were not one of the primary factors considered in the         
                                                                      
federal government's choice of reservation lands, and many tribes were         
                                                                      
removed to reservations located far from their traditional hunting grounds.    
                                                                      
In response to a strong desire on the part of tribes to retain access to       
                                                                      
these areas, treaties with Northwest Indians provided for . . . "the           
                                                                      
privilege of hunting . . .  on open and unclaimed lands{.}"  In essence,       
                                                                      
these treaty provisions preserved a portion of the aboriginal rights           
                                                                      
exercised by the signatory tribes.                                             
                                                                      
                                                                               
                                                                      
Nye, supra, at 177-78 (footnotes omitted).  See also Reynolds, supra, at       
                                                                      
752 (because the tribes could have reserved their aboriginal hunting and       
                                                                      
fishing rights only on lands which they actually hunted and fished at the      
                                                                      
time of the treaty, the primary inquiry must determine whether the area        
                                                                      
allegedly protected by the treaty formed part of the tribe's aboriginal        
                                                                      
territory).                                                                    
                                                                      
     To determine the existence of original Indian title to land, and the      
                                                                      
right to hunt and fish following from that title, courts have generally        
                                                                      
required a showing of actual use and occupancy over an extended period of      
                                                                      
time.  In Mitchel v. United States {34 U.S. (9 Pet.) 711 (1835)} the United    
                                                                      
States Supreme Court said:                                                     
                                                                      
     Indian possession or occupation was considered with reference to their    
                                                                      
habits and modes of life; their hunting grounds were as much in their          
                                                                      
actual possession as the cleared fields of the whites; and their rights to     
                                                                      
its exclusive enjoyment in their own way and for their own purposes were as    
                                                                      
much respected, until they abandoned them, made a cession to the               
                                                                      
government, or an authorized sale to individuals.                              
                                                                      
In claims against the United States based upon original title, a               
                                                                      
requirement of exclusive use and occupancy has been satisfied by a showing     
                                                                      
that two or more tribes jointly or amicably hunted in the same area to the     
                                                                      
exclusion of others. . . .                                                     
                                                                      
     The existence of aboriginal hunting and fishing rights, however, does     
                                                                      
not necessarily turn upon the existence of original title to lands and is      
                                                                      
not dependent upon recognition in a treaty or act of Congress.  Aboriginal     
                                                                      
rights remain in the Indians unless granted to the United States by treaty,    
                                                                      
abandoned, or extinguished by statute.  When a treaty has been signed,         
                                                                      
aboriginal use may still be important to determine the extent of the rights    
                                                                      
reserved under the treaty.                                                     
                                                                      
                                                                               
                                                                      
Cohen, supra, at 442-43 (footnotes omitted).                                   
                                                                      
     There is no evidence in the record on appeal to support a finding that    
                                                                      
the Nooksack Tribe actually occupied or used, over an extended period of       
                                                                      
time, the Oak Creek Wildlife Area for hunting.  The only area which the        
                                                                      
record shows the Tribe clearly used for hunting lies within the lands ceded    
                                                                      
to the United States in the treaty.                                            
                                                                      
     Defendant Buchanan argues that the Tribe's right to hunt does not         
                                                                      
depend on proof of aboriginal title or preexisting hunting practices and       
                                                                      
grounds.  Instead, he claims the hunting right is based not on aboriginal      
                                                                      
title but on the treaty.  In support of this argument, Buchanan points to      
                                                                      
fishing rights cases which interpret the phrase "usual and accustomed          
                                                                      
grounds and stations."  These cases, he argues demonstrate that the treaty     
                                                                      
right to hunt or fish does not depend on aboriginal title or use.  Buchanan    
                                                                      
additionally argues that the treaty fishing right is a limited one that        
                                                                      
permits fishing only at the usual and accustomed places, but that the          
                                                                      
hunting right is limited only to "open and unclaimed lands."                   
                                                                      
     The treaty fishing right which was reserved by the Indians in the         
                                                                      
Stevens Treaties has been interpreted to provide a broad right to treaty       
                                                                      
tribes to fish outside of their ceded lands in all usual and accustomed        
                                                                      
fishing areas, without regard to whether these areas were part of the usual    
                                                                      
habitat of the tribe and without regard to whether there had been              
                                                                      
consistent and exclusive use of the areas.  United States v. Washington,       
                                                                      
384 F. Supp. at 332; Fishing Vessel, 443 U.S. at 666.  The treaty fishing      
                                                                      
right has been interpreted as insuring tribes a right to a fixed percentage    
                                                                      
of the number of harvestable fish, United States v. Washington, 384 F.         
                                                                      
Supp. at 343, and, further, interpreting the right as a permanent one,         
                                                                      
unless abrogated by Congress.  United States v. Washington, 384 F. Supp. at    
                                                                      
331-32.                                                                        
                                                                      
     In contrast, the treaty hunting right, by its terms, is of a temporary    
                                                                      
and self-limiting nature.  The right was intended to diminish as lands         
                                                                      
became settled, without the need of congressional action.  See, e.g.,          
                                                                      
Hicks, 587 F. Supp. at 1165.  The treaty hunting clause contained in the       
                                                                      
Stevens Treaties has not received the extent of analysis to which the          
                                                                      
fishing clause has been subjected and, although State v. Chambers, 81 Wn.2d    
                                                                      
929, noted that the defendant, a Yakama tribal member, killed a deer on        
                                                                      
privately-owned property at least 40 miles from the nearest territory ceded    
                                                                      
to the United States by the Yakamas in their treaty, the issue now before      
                                                                      
us has not previously been squarely addressed by this court.  See also         
                                                                      
Hicks, 587 F. Supp. at 1164.                                                   
                                                                      
     The Supreme Courts of Idaho and Montana, interpreting Stevens             
                                                                      
Treaties, have held the treaty right is a reserved right  "to hunt upon        
                                                                      
open and unclaimed land . . . at any time of the year in any of the lands      
                                                                      
ceded to the federal government though such lands are outside the boundary     
                                                                      
of their reservation."  Arthur, 74 Idaho at 265; see also State v. Coffee,     
                                                                      
97 Idaho 905, 556 P.2d 1185 (1976); State v. Stasso, 172 Mont. 242, 563        
                                                                      
P.2d 562 (1977) (relying on the Idaho cases).                                  
                                                                      
     Mr. Nye provides the following analysis:                                  
                                                                      
Treaty clauses reserving Indian rights to hunt on "open and unclaimed          
                                                                      
lands" . . . do not expressly limit these rights to ceded lands.  However,     
                                                                      
treaties were reservations of aboriginal rights, and both the signatory        
                                                                      
tribes and the federal treaty negotiators understood that rights of access     
                                                                      
would be limited to traditional hunting grounds which remained "open and       
                                                                      
unclaimed" or "unoccupied."                                                    
                                                                      
     . . .  If the principles of treaty construction are strictly followed     
                                                                      
. . . the right should be limited to the aboriginal hunting grounds of the     
                                                                      
signatory Indians.  This line of demarcation should be based not on the        
                                                                      
treaty descriptions, but on other evidence which better captures the           
                                                                      
understanding of the Indians upon entering the treaty.  Any line drawn must    
                                                                      
necessarily be approximate, and the principles of treaty interpretation        
                                                                      
require that any ambiguous questions be resolved in favor of the Indians.      
                                                                      
                                                                               
                                                                      
Nye, supra, at 190-91 (footnotes omitted).                                     
                                                                      
     The geographic scope of the hunting right cannot be resolved from the     
                                                                      
language of the treaty alone.  We hold that application of the reservation     
                                                                      
of rights doctrine is the more legally sound approach to interpreting the      
                                                                      
hunting rights provision of the Treaty of Point Elliott.  Under such an        
                                                                      
analysis, open and unclaimed lands within the aboriginal hunting grounds of    
                                                                      
the Nooksack Tribe are reserved under the treaty for hunting by tribal         
                                                                      
members, so long as the lands remain open and unclaimed.  The geographic       
                                                                      
area available for hunting would certainly include the territory ceded to      
                                                                      
the United States and described in article I of the Treaty of Point            
                                                                      
Elliott, and may include other areas if those areas are proven to have been    
                                                                      
actually used for hunting and occupied by the Nooksack Tribe over an           
                                                                      
extended period of time.  Because the trial court did not so limit the         
                                                                      
geographic scope of the Nooksack's treaty, we reverse the dismissal of the     
                                                                      
charges against defendant Buchanan.  However, we hold that, on remand, the     
                                                                      
defendant should have the opportunity to prove that the Nooksack Tribe's       
                                                                      
aboriginal hunting grounds include the land within the Oak Creek Wildlife      
                                                                      
Area.                                                                          
                                                                      
We next consider whether the Oak Creek Wildlife Area is "open and unclaimed    
                                                                      
land" under the meaning of the Treaty of Point Elliott.                        
                                                                      
     Under article 5 of the treaty, the Nooksack Tribe has a right to hunt     
                                                                      
on open and unclaimed lands.  The United States Supreme Court has held that    
                                                                      
the treaty right to hunt, like the treaty right to fish, may only be           
                                                                      
regulated by the state "in the interest of conservation, provided the          
                                                                      
regulation meets appropriate standards and does not discriminate against       
                                                                      
the Indians."  Antoine, 420 U.S. at 207 (citing Puyallup Tribe v.              
                                                                      
Department of Game, 391 U.S. 392, 398, 88 S. Ct. 1725, 20 L. Ed. 2d 689        
                                                                      
(1968)).  The "appropriate standards" requirement obligates the state to       
                                                                      
prove that its regulation is a "reasonable and necessary conservation          
                                                                      
measure, and that its application to the Indians is necessary in the           
                                                                      
interest of conservation."  Antoine, 420 U.S at 207 (citation omitted).        
                                                                      
See also Miller, 102 Wn.2d at 688 n.5 ("We do not read Antoine as giving       
                                                                      
Indians the exclusive right to hunt, but rather as ensuring that their         
                                                                      
right to hunt is not impaired for purposes other than those of                 
                                                                      
conservation.")                                                                
                                                                      
     The trial court entered a finding of fact stating that the State had      
                                                                      
not produced any evidence that the treaty tribe hunters were capable of        
                                                                      
having a significant impact on the elk population in the Oak Creek area or     
                                                                      
in the State of Washington and, further, that the State had failed to          
                                                                      
sustain its burden of proving that the application of its regulations to       
                                                                      
Nooksack Indians or to Point Elliott Treaty hunters is necessary for           
                                                                      
conservation.  The State did not assign error to this finding and,             
                                                                      
therefore, it is a verity on appeal.  State v. Smith, 130 Wn.2d 215, 223,      
                                                                      
922 P.2d 811 (1996); State v. Echeverria, 85 Wn. App. 777, 783, 934 P.2d       
                                                                      
1214 (1997).  The question of whether the State's regulations, which closed    
                                                                      
the hunting season, restricted the taking of antlered elk and established a    
                                                                      
winter feeding station, are necessary conservation measures is not properly    
                                                                      
before the court.                                                              
                                                                      
     We limit our inquiry to whether the Oak Creek Wildlife Area is open       
                                                                      
and unclaimed land within the meaning of the Treaty of Point Elliott.          
                                                                      
     This court has previously interpreted the meaning of  "open and           
                                                                      
unclaimed lands" as that term is used in Stevens Treaties in two decisions.    
                                                                      
Under both decisions, publicly-owned lands are considered "open and            
                                                                      
unclaimed."  In Miller, 102 Wn.2d at 680 n.2, the court held that national     
                                                                      
forest land is "open and unclaimed" land within the meaning of the treaty.     
                                                                      
In Chambers, 81 Wn.2d at 936, this court approved a jury instruction           
                                                                      
defining "open and unclaimed lands" as "lands which are not in private         
                                                                      
ownership."  These decisions are consistent with those of other                
                                                                      
jurisdictions interpreting Stevens Treaties.  See Stasso, 172 Mont. at 248     
                                                                      
(national forest service lands that have not been patented to a private        
                                                                      
person are open and unclaimed lands within the meaning of a Stevens            
                                                                      
Treaty); Arthur, 74 Idaho at 261 (the term "open and unclaimed" land as        
                                                                      
used in a Stevens Treaty was intended to include and embrace such lands as     
                                                                      
were not settled and occupied by the whites under possessory rights or         
                                                                      
patent or otherwise appropriated to private ownership and may include          
                                                                      
national forest reserve lands); Coffee, 97 Idaho 905 (privately-owned land     
                                                                      
is not open and unclaimed within the meaning of a Stevens Treaty);             
                                                                      
Confederated Tribes of Umatilla Indian Reservation v. Maison, 262 F. Supp.     
                                                                      
871 (D. Ore. 1966) (national forests lands considered open and unclaimed       
                                                                      
under the terms of a Stevens Treaty), aff'd sub nom. Holcomb v.                
                                                                      
Confederated Tribes of Umatilla Indian Reservation, 382 F.2d 1013 (9th Cir.    
                                                                      
1967).  See also Hicks, 587 F. Supp. at 1165 (trial court opined that the      
                                                                      
construction of "open and unclaimed lands" that best accommodates Indian       
                                                                      
hunting as settlement occurs and matures is that "open and unclaimed lands"    
                                                                      
include public lands put to uses consistent with an Indian hunting             
                                                                      
privilege).                                                                    
                                                                      
The State, relying on Hicks, argues that once the hunting regulations with     
                                                                      
respect to elk went into effect, the use of the Oak Creek Wildlife Area for    
                                                                      
hunting was not a compatible use and, therefore, the lands were not open       
                                                                      
and unclaimed.  Our acceptance of this argument would permit the State to      
                                                                      
avoid its burden of proving that regulations imposed on Indian treaty          
                                                                      
hunters are necessary for conservation purposes.  See Miller, 102 Wn.2d at     
                                                                      
688.  The State has designated the Oak Creek Wildlife Area for use for         
                                                                      
hunting, fishing and recreation.  Limits on these activities in the Oak        
                                                                      
Creek Wildlife Area are by State regulation.  The regulations must comply      
                                                                      
with standards developed by this court and the United States Supreme Court,    
                                                                      
and be necessary for conservation if the regulations are restrictive of        
                                                                      
treaty rights.  The trial court's unchallenged finding in this case is that    
                                                                      
the State has not met its burden in this regard.8                              
                                                                      
     The State also relies on State v. Cutler, 109 Idaho 448, 708 P.2d 853     
                                                                      
(1985), to support its argument that lands which are located in a State-       
                                                                      
owned wildlife area which is operated as a wintering range for elk and deer    
                                                                      
are not "open and unclaimed."  The treaty interpreted in Cutler  was not a     
                                                                      
Stevens Treaty and the pertinent language of the treaty provided the           
                                                                      
Indians had the right to hunt on "unoccupied lands of the United States."      
                                                                      
The Cutler  court held that the state wildlife area, which was converted       
                                                                      
from a privately-owned ranch, was "occupied" by the State of Idaho and that    
                                                                      
sufficient indicia of occupancy existed (fences, signs, cattle guards,         
                                                                      
cultivated fields, machinery, roads, campgrounds and buildings) to put the     
                                                                      
Indian hunters on notice that the land was not "unoccupied lands of the        
                                                                      
United States."  Cutler, 109 Idaho at 454.  The State offered no evidence      
                                                                      
in this case that would bring it within the rationale of Cutler.               
                                                                      
     From the rulings in the various cases which discuss the issue, and in     
                                                                      
light of the treaty language, we discern that a general statement of the       
                                                                      
rule is that publicly-owned lands, which are not obviously occupied and        
                                                                      
which are put to a use which is compatible with hunting, are "open and         
                                                                      
unclaimed lands" under the terms of the Stevens Treaties.  Treaty hunters      
                                                                      
have a right to hunt on such lands, unrestricted by State regulation,          
                                                                      
unless the regulations are necessary for conservation purposes.  Miller,       
                                                                      
102 Wn.2d 678.  In this case, the Oak Creek Wildlife Area is publicly          
                                                                      
owned, is obviously unoccupied, and its purposes are compatible with and,      
                                                                      
in fact, include hunting.  The trial court and Court of Appeals correctly      
                                                                      
determined that the Oak Creek Wildlife Area is open and unclaimed land.        
                                                                      
Finally, the State urges this court to hold that the federal statute           
                                                                      
creating the State of Washington and admitting the state "into the Union on    
                                                                      
an equal footing with the original States," Act of February 22, 1889, 25       
                                                                      
Stat. 676, 678, impliedly abrogated the treaty hunting rights of Indians       
                                                                      
living in Washington.                                                          
                                                                      
     In support of its argument the State primarily relies on Ward v. Race     
                                                                      
Horse, 163 U.S. 504, 16 S. Ct. 1076, 41 L. Ed. 244 (1896), a case in which     
                                                                      
the Supreme Court held that Congress, in admitting Wyoming to the Union on     
                                                                      
equal footing with the original states, effectively abrogated the Indian       
                                                                      
treaty hunting rights of certain treaty Indians in Wyoming.  See also Crow     
                                                                      
Tribe of Indians v. Repsis, 73 F.3d 982 (10th Cir. 1995) (applying Race        
                                                                      
Horse to another treaty applicable to tribes residing within the State of      
                                                                      
Wyoming); McCoy, 63 Wn.2d 421 (where this court held the treaty fishing        
                                                                      
rights of Indians who were parties to the Treaty of Point Elliott were         
                                                                      
impliedly abrogated by Washington's admission to the Union).                   
                                                                      
After oral argument in this case, the United States Supreme Court              
                                                                      
effectively overruled Race Horse in Minnesota v. Mille Lacs, 1999 WL 155689    
                                                                      
(Rehnquist, C.J., dissenting) (noting the majority's "apparent overruling      
                                                                      
sub silentio" of Race Horse).  The Supreme Court rejected use of the equal     
                                                                      
footing language to find an abrogation of Indian treaty rights, holding        
                                                                      
"treaty rights are not impliedly terminated upon statehood."  Mille Lacs,      
                                                                      
1999 WL 155689, at *2.                                                         
                                                                      
     This decision is consistent with the decisions over the past 100          
                                                                      
years, since Race Horse  was decided, in which the Supreme Court has           
                                                                      
clarified and refined the law governing interpretation and abrogation of       
                                                                      
Indian treaty hunting and fishing rights.  In contrast to the language in      
                                                                      
Race Horse, where the Court discussed the treaty's "grant" of rights to the    
                                                                      
Indians, the Supreme Court now views the grant as one from the Indians,        
                                                                      
with a reservation of rights not granted.  Winans, 198 U.S. at 381; Fishing    
                                                                      
Vessel, 443 U.S. at 680.  The Court has further stated that although           
                                                                      
Congress has the sole power to eliminate a treaty right, South Dakota v.       
                                                                      
Yankton Sioux Tribe,     U.S.    , 118 S. Ct. 789, 798, 139 L. Ed. 2d 773      
                                                                      
(1998), its intention to abrogate Indian treaty rights must be clear and       
                                                                      
plain.  United States v. Dion, 476 U.S. 734, 738, 106 S. Ct. 2216, 90 L.       
                                                                      
Ed. 2d 767 (1986).  Absent explicit statutory language, the Court is           
                                                                      
"extremely reluctant" to find congressional abrogation of treaty rights.       
                                                                      
Fishing Vessel, 443 U.S. at 690.  It therefore will not construe statutes      
                                                                      
as abrogating a treaty right in a backhanded way but will require "clear       
                                                                      
evidence that Congress actually considered the conflict between its            
                                                                      
intended action on the one hand and Indian treaty rights on the other, and     
                                                                      
chose to resolve that conflict by abrogating the treaty."  Dion, 476 U.S.      
                                                                      
at 739-40.                                                                     
                                                                      
     Furthermore, the Supreme Court has undermined the premise upon which      
                                                                      
Race Horse was decided by holding that "treaty rights to hunt, fish . . .      
                                                                      
are not irreconcilable with a State's sovereignty over the natural             
                                                                      
resources in the State."  Mille Lacs, 1999 WL 155689, at *19.  Washington's    
                                                                      
enabling act, 25 Stat. 676 (1889), differs from the statute admitting          
                                                                      
Wyoming to the Union, in that the statute admitting Washington reserves        
                                                                      
from Washington the right to control lands owned or held by any Indian or      
                                                                      
Indian tribe.  25 Stat. 676-77 (1889).  This clause makes it clear that        
                                                                      
Congress had the Indians' treaty rights in mind when it created the State      
                                                                      
of Washington, but did not go on to expressly abrogate the treaty hunting      
                                                                      
rights.  Under Dion and Mille Lacs, we are unable to hold that, in the         
                                                                      
enabling act, Congress impliedly abrogated Indian treaty rights.  Fishing      
                                                                      
Vessel, 443 U.S. at 690.                                                       
                                                                      
     Reversed.                                                                 
                                                                      
                                                                               
                                                                      
WE CONCUR:                                                                     
                                                                      
                                                                               
                                                                      
1 Treaty Between the United States and the Dwamish, Suquamish, and other       
                                                                      
allied and subordinate Tribes of Indians in Washington Territory, Jan. 22,     
                                                                      
1855, 12 Stat. 927.                                                            
                                                                      
2 Former RCW 77.16.020(1) provided in pertinent part:  "It is unlawful to      
                                                                      
hunt, fish, possess, or control a species of game bird, game animal, or        
                                                                      
game fish during the closed season for that species."  Laws of 1987, ch.       
                                                                      
506, sec. 59.  Former RCW 77.21.010(1) provided that a subsequent violation    
                                                                      
of the hunting laws must be prosecuted and punished as a Class C felony.       
                                                                      
Laws of 1988, ch. 265, sec. 3.  Former RCW 77.21.060(2) provided, in           
                                                                      
pertinent part, that it was "unlawful for a person to conduct an activity      
                                                                      
requiring a wildlife license, tag, or stamp for which they have had a
license forfeiture{.}" Laws of 1989, ch. 314, sec. 6.  In 1998 the             
                                                                      
Legislature revised and recodified the criminal laws governing the taking      
                                                                      
of fish and wildlife.  Laws of 1998, ch. 190.  The prohibitions and            
                                                                      
penalties have not changed.  See RCW 77.15.410 (unlawful hunting of big        
                                                                      
game); RCW 77.15.670 (unlawful hunting while hunting privileges revoked).      
                                                                      
3 The tribes joining in the amicus brief are the Squaxin Island Tribe,         
                                                                      
Tulalip Tribes, Nisqually Indian Tribe, Port Gamble, Jamestown and Lower       
                                                                      
Elwha Bands of S'Klallam for the Skokomish Tribe, Puyallup Tribe, Upper        
                                                                      
Skagit Tribe, Sauk-Suiattle Tribe, Stillaguamish Tribes, Swinomish Indian      
                                                                      
Tribal Community, Suquamish Tribe, Yakama Indian Nation, Lummi Tribe,          
                                                                      
Nooksack Tribe, and Muckleshoot Indian Tribe.                                  
                                                                      
4 The first of the so-called "Boldt decisions" is set forth in United          
                                                                      
States v. Washington, 384 F. Supp. 312 (W.D. Wash. 1974).  The underlying      
                                                                      
litigation and the Boldt decision orders have been the subject of numerous     
                                                                      
actions in both Washington and federal courts.   Puget Sound Gillnetters       
                                                                      
Ass'n v. Moos, 92 Wn.2d 939, 603 P.2d 819 (1979), traces the history of the    
                                                                      
litigation through 1979.                                                       
                                                                      
5 In addition to what is now Washington State, Washington Territory            
                                                                      
included parts of Idaho, Montana and Oregon.  See Charles F. Wilkinson,        
                                                                      
Indian Tribal Rights and the National Forests: The Case of the Aboriginal      
                                                                      
Lands of the Nez Perce Tribe, 34 Idaho L. Rev. 435, 436-37 (1998).             
                                                                      
6 In some of the treaties the language with respect to shellfish is            
                                                                      
omitted.  See, e.g., Treaty Between the United States and the Walla-Walla,     
                                                                      
Cayuses, and Umatilla Tribes and Bands of Indians in Washington and Oregon     
                                                                      
Territories, June 9, 1855, art. I, 12 Stat. 945, 946 {hereinafter Treaty       
                                                                      
Between the Walla-Wallas}; Treaty Between the United States and the Yakama     
                                                                      
Nation of Indians, June 9, 1855, art. III, para. 2, 12 Stat. 951, 953          
                                                                      
{hereinafter Treaty Between the Yakamas}; Treaty Between the United States     
                                                                      
and the Nez Percİ Indians, June 11, 1855, art. III, para. 2, 12 Stat. 957,     
                                                                      
958 {hereinafter Treaty Between the Nez Percİ}; Treaty Between the United      
                                                                      
States and the Flathead, Kootenay and Upper Pend d'Oreilles Indians, July      
                                                                      
16, 1855, art. III, para. 2, 12 Stat. 975, 976 {hereinafter Treaty Between     
                                                                      
the Flatheads}.  In some the privilege to hunt and gather roots and berries    
                                                                      
also includes the right to pasture cattle and horses on open and unclaimed     
                                                                      
land.  See, e.g., Treaty Between the Walla-Wallas, 12 Stat. at 946; Treaty     
                                                                      
Between the Yakamas, 12 Stat. at 953; Treaty Between the Nez Percİ, 12         
                                                                      
Stat. at 958; Treaty Between the United States and the Qui-nai-elt and Quil-   
                                                                      
leh-ute Indians, Jan. 25, 1856, art. III, 12 Stat. 971, 972; Treaty Between    
                                                                      
the Flatheads, 12 Stat. at 976.  The Treaty between the United States and      
                                                                      
the Makah Tribe also secures to the tribe the right of whaling or sealing      
                                                                      
at usual and accustomed grounds.  Treaty Between the United States and the     
                                                                      
Makah Tribe of Indians, Jan. 31, 1855, art. IV, 12 Stat. 939, 940.             
                                                                      
7 In 1994, the Yakima Indian Nation adopted the spelling of Yakama.  See       
                                                                      
State v. Price, 87 Wn. App. 424, 425 n.1, 942 P.2d 377 (1997).  This           
                                                                      
spelling is used throughout this opinion when referring to the Yakama          
                                                                      
Nation, except where the spelling "Yakima" appears in the title of an          
                                                                      
article or case.                                                               
                                                                      
8 Amicus Department of Fish and Wildlife additionally argues that the          
                                                                      
status of the land changes as regulations of the State change to close,        
                                                                      
control, restrict or otherwise put land to uses inconsistent with hunting.     
                                                                      
In essence, the Department argues that the land is open and unclaimed for      
                                                                      
elk hunting during the State's elk hunting season, but changes its status      
                                                                      
when State regulation closes the season in that particular area.  This         
                                                                      
argument ignores established law governing when a State, by hunting            
                                                                      
regulations, can restrict treaty rights.  See Antoine v. Washington, 420       
                                                                      
U.S. 194, 206, 95 S. Ct. 944, 43 L. Ed. 2d 129 (1975); State v. McCormack,     
                                                                      
117 Wn.2d 141, 143, 812 P.2d 483 (1991).