In United States v. Sioux Nation of Indians, 448 U.S. 371, 100 S. Ct. 2716, 65 L. Ed. 2d 844 (1980), the petitioners had filed a claim for compensation in the Court of Claims for the taking of tribal lands in violation of a treaty between the United States and the tribe. Id. at 384. The Court of Claims dismissed the matter, finding that it was not authorized to reach the merits of the claim. Id. Congress passed a new act creating the Indian Claims Commission and the petitioners filed their claim again. Id. at 384-85. The Commission determined that Congress's seizure of tribal land in violation of a prior treaty was a taking and ordered just compensation pursuant to the Fifth Amendment. Id. at 386. On appeal to the Court of Claims, the United States successfully argued that a portion of the claim was barred by res judicata and collateral estoppel because of the prior unsuccessful action that the petitioners had filed. Id. at 387-88. Congress subsequently enacted a statute requiring the Court of Claims to "review the merits of the Indian Claims Commission's judgment . . . without regard to the defenses of res judicata and collateral estoppel." Id. at 389. The Court of Claims was authorized to take new evidence and review the merits of the Indian Claims Commission's judgment de novo. Id. The Court of Claims ruled in favor of the petitioners, and the Supreme Court granted the United States' petition for certiorari. Id. at 390.