 The "Passamaquoddy" decision is binding only in the First Circuit, which includes the U.S. states of Maine, New Hampshire, Massachusetts, and Rhode Island, and the settlement act extinguished any further aboriginal title litigation in Maine.The Narragansetts were an early beneficiary of the "Passamaquoddy" precedent.In an opinion striking all the defendants' affirmative defenses against the Narragansett land claim, the Rhode Island district court noted that "[our] task has been greatly simplified by the First Circuit's analysis of the [Nonintercourse] Act in" "Passamaquoddy".