g to Wall Street forecasts, spending on gambling will double within a decade. Twenty states now have Indian gambling, with gambling services ranging from bingo parlors to casinos as big and glamorous as those in Nevada. Fifty eight tribes are currently involved in gaming ventures, and these venues have become important in some states. For instance, the Foxwoods casino in Connecticut is the single largest contributor to that state's tax coffers, and alone it will provide the state with $113 million in 1994. Minnesota currently has more casinos than Atlantic City, all under the 'gis of native American tribes. The use of reservation lands for large scale commercial gaming designed to attract non Indian players is a relatively new trend, and two court cases from the early 1980s set the standard for states to follow in regulating these establishments. One was Seminole Tribe v. Butterworth (from Florida) and the other State of California v. Cabazon, and in both cases the courts used the "criminal prohibitory and civil regulatory" test, which holds that if state law criminally prohibits a form of gambling, then the tribes within that state may not engage in that form of gaming free of state control. Congress passed the federal Indian Gaming Regulatory Act in 1988 as a way of further regulating Native American gaming. This legislation affirms Indian sovereignty over gaming based on
provisions established by the country's first interactions with tribal entities. It was Supreme Court Justice John Marshall who shaped the earliest federal policy toward Native Americans at the beginning of the nineteenth century, and he wrote that Indian tribes are "domestic dependent nations, recognized as sovereign within their territories, with power of self government over activities on their reservations." The legal ramifications of this position have proved to be complex, and subject to modifications by the reservations' federally appointed tru...