He died in 1944, in Washington, D. C. In 1934, Congress passed the Wheeler-Howard Bill, also known as the Indian Reorganization Act, a significant victory for advocates like John Collier and Gertrude Bonnin, who had long battled against exploiters like Albert B.

Despite facing opposition from figures like Fall and Burke, who prioritized business interests over Native American welfare, the reformers managed to secure some improvements during the 1920s.

The momentum of the New Deal era eventually propelled the passage of the Indian Reorganization Act, granting tribes more autonomy and resources.

Fall and his ally Charles H. Burke were prominent figures representing the obscurantist faction, prioritizing business interests over Native American rights.

Despite their efforts to suppress Native American culture and religion, the reform movement gained traction, eventually leading to legislative victories such as the Indian Reorganization Act.