Franklin Ducheneaux, Cheyenne River Sioux, played a crucial role in crafting virtually every landmark piece of Native American legislation before Congress, including the Indian Self-Determination and Education Assistance Act of 1975, the Indian Health Care Improvement Act, the American Indian Religious Freedom Act, the Indian Child Welfare Act, the 1982 Indian Mineral Development Act, and, in 1990, the Native American Graves Repatriation Act.