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The Reindeer Industry Act of 1937 established a de facto Native Alaskan monopoly in the reindeer industry as a means of subsistence that would allow Native Alaskans to remain self-sufficient and continue to practice their traditional customs. In 1997, the Ninth Circuit held that the Reindeer Act did not preclude nonNatives from owning and selling reindeer, thereby opening the reindeer industry up to non-Natives. The unique Native Alaskan culture of the Seward Peninsula, which depends upon the reindeer industry, is in jeopardy as a result of competition it now faces from non-Natives. The federal government has a fiduciary obligation to protect the cultural welfare of Native Alaskans as a result of the trust relationship that exists between the federal government and Native Americans. The federal government has yet to take action to fulfill that fiduciary obligation to the Native Alaskan reindeer herders of the Seward Peninsula.

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