 The United States Court of Appeals for the First Circuit held that the Nonintercourse Act applied to the Passamaquoddy and Penobscot, non-federally-recognized Indian tribes, and established a trust relationship between those tribes and the federal government that the state of Maine could not terminate.By upholding a declaratory judgement of the United States District Court for the District of Maine, the First Circuit cleared the way for the Passamaquoddy and Penobscot to oblige the federal government to bring a land claim on their behalf for approximately 60% of Maine, an area populated by 350,000 non-Indians.According to the Department of Justice, the suit was "potentially the most complex litigation ever brought in the federal courts with social and economic impacts without precedent and incredible potential litigation costs to all parties."