Lyng v. Northwest Indian Cemetery Protective Association, in 1988, denied the Yurok, Tolowa, and Karok tribes their rights to religious freedom under the first amendment by ruling in favor of the United States Forest Service.
When Arnold and Reed accepted positions as so-called field matrons on the Hoopa Valley Indian Reservation in the Klamath River Valley of Northern California, they were charged to exert a “civilizing influence” upon the fewer than eight hundred members of the Karok nation, a vagueness they were to exploit to their own benefit and that of the Karok.