 However, when both the Act and the legislative history are unsuccessful in providing proof that supports the idea of diminishment, the court holds that the reservation is not diminished

The important precedents set in the decision, "Solem v. Bartlett", were heavily relied upon later on to decide two other cases involving Indian country jurisdiction.In "Hagen v. Utah", the court, using the factors determined in Solem, upheld that Congress had intentionally diminished tribal lands with surplus land acts in the Uintah Reservation.The court determined that the specific language in Hagen, which addressed that the excess lands “be restored to the public domain” clearly indicated that the land was not to remain reservation land as in Solem, but instead reduce the boundaries of the reservation.