 Paterson and David Roseman—who, as Deputy and Assistant Attorneys General for the State of Maine, respectively, were involved in the litigation—published a law review article criticizing the First Circuit's "Passamaquoddy" decision.Paterson and Roseman argued that the Nonintercourse Act's restriction on land purchases from tribes was not meant to apply to land within the territory of a U.S. state.According to Paterson and Roseman, "[n]either the district nor circuit courts in "Passamaquoddy v. Morton" had all the available legislative history, administrative rulings, legal analysis or case law necessary to make a fully informed decision."