 In the Supreme Court case "Matter of Heff", the decision clarified that a Native American granted citizenship through the Dawes Act is immediately a citizen of the U.S. and his state.The 1897 amendment banning alcohol was considered a police statute, where power lies with the state and not Congress, and therefore would not apply to such a citizen.Representative of South Dakota, Charles H. Burke, saw the need to correct the situation in order to protect Native Americans from the sale of liquor.