 The crime had occurred on the area of the reservation that had been opened to settlement in 1908 with Cheyenne River Act (465 U. S. 465).Bartlett pleaded guilty and was sentenced to ten years in a state penitentiary, but contended that his crime actually took place in Indian country because the Act did not reduce the reservation but instead only opened it to settlement, therefore the jurisdiction belonged to the tribe, not the state (465 U.S. 465).The Court recognized that large areas in the west had been set aside as Indian reservations in the late 19th century, and that later, individual allotments were designated to Indians, with the excess land being sold to non-Indians.