The New York courts held that the 1788 Phelps and Gorham Purchase did not violate the Nonintercourse Act, one of the provisions of which prohibits purchases of Indian lands without the approval of the federal government, and that (even if it did) the Seneca Nation of New York was barred by the state statute of limitations from challenging the transfer of title.

According to O'Toole and Tureen, "Christy is an important case in that it revived the concept that states had special powers to deal with Indian tribes within their borders.

Modern federal courts hold that only Congress can ratify a conveyance of aboriginal title, and only with a clear statement, rather than implicitly.

[4] In 1827, the money was deposited in Ontario Bank in Canandaigua, New York, and in 1855 it was paid to the United States treasury, which began remitting the interest to the Seneca Nation.

[6] The Seneca filed a petition with the Bureau of Indian Affairs on January 5, 1881, requesting restoration and possession of certain lands related to the Phelps and Gorham Purchase.

[7] The Seneca contended that the purchase was invalid because the treaty was not approved by the Senate, as required by the Constitution; therefore it violated the Nonintercourse Act.

[5] Christy's "answer consisted of a general denial, the plea of the statute of limitations of 20 years, and that the plaintiff had not the legal right, title, capacity, or authority to maintain the action.

"[11] As to the second question, the court noted: The suggestion that the entire amount of the purchase money was not paid, and that such fact is in the way of supporting the claim to the Indian title, is not sustained.

This right, however, was more than 40 years ago conferred by statute, which, among other things, provides that the Seneca Nation of Indians may maintain any action of ejectment to recover the possession of any part of the Allegany and Cattaraugus reservations unlawfully withheld from them.

He said: "It is material to observe that there was no uniform procedure on the part of the purchasers from Massachusetts in acquiring the Indian title," and gave examples of conveyances he believed to have been implicitly ratified by the federal government.

But the proviso does not require that the treaty should be one between the United States and the tribe from whom the purchase is made, as in the cases coming under the first clause of the section.

[21]Andrews also placed reliance on the fact that later versions of the Act excluded the clause "or to any state, whether having the right of pre-emption or not" and instead simply prohibited acquisitions by persons.

[22]Andrews emphasized this latter ground because of his desire to prevent any similar lands claims by Indian tribes: In view of the numerous Indian titles in this state originating in treaties by the state, or in purchases made with its sanction by individuals, we prefer to place our judgment on the broader ground, which will remove any cloud upon the validity of those titles.

After reviewing the facts and the judgment below, he wrote that: The proper construction of this enabling act, and the time within which an action might be brought and maintained thereunder, it was the province of the state courts to determine.

The Seneca Nation availed itself of the act in bringing this action, which was subject to the provision, as held by the court of appeals, that it could only be brought and maintained ‘in the same manner and within the same time as if brought by citizens of this state in relation to their private individual property and rights.’ Under the circumstances, the fact that the plaintiff was an Indian tribe cannot make federal questions of the correct construction of the act and the bar of the statute of limitations.