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Rh U. S., at 296–297; see also Cobell v. Norton, 240 F. 3d 1081, 1086 (CADC 2001); Shoshone Indian Tribe of Wind River Reservation v. United States, 364 F. 3d 1339, 1348 (CA Fed. 2004).

In United States v. Jicarilla Apache Nation, 564 U. S. 162 (2011), the Court took steps to rectify this confusion. There, we explained that the Federal Government is “not a private trustee” but a “sovereign,” id., at 173–174, and that “[t]he Government assumes Indian trust responsibilities only to the extent it expressly accepts those responsibilities by statute,” id., at 177. Accordingly, any legal trusts established or duties self-imposed by the Government for a tribe’s benefit are “defined and governed by statutes rather than the common law.” Id., at 174; see also id., at 173 (emphasizing that “ ‘[t]he general relationship between the United States and the Indian tribes is not comparable to a private trust relationship’ ”). The Court’s opinion today represents a step in the same direction, making clear that tribes’ legal claims against the Government must be based on specific provisions of positive law, not merely an amorphous “trust relationship.”

However, the Court has also invoked the “trust relationship” to shape at least two other areas of its Indian-law jurisprudence—with questionable results. For example, the Court has identified “the unique trust relationship” with the Indians as the source of pro-Indian “canons of construction” that are supposedly “applicable [only] in Indian law.” County of Oneida v. Oneida Indian Nation of N. Y., 470 U. S. 226, 247 (1985); see also EEOC v. Karuk Tribe Housing Auth., 260 F. 3d 1071, 1081 (CA9 2001) (refusing to apply the Age Discrimination in Employment Act of 1967 to tribes in part because of those canons). But it is far from clear how such a trust relationship would support different interpretive tools. The first cases to apply those pro-Indian canons did not ground them in any “trust relationship,” but in the more basic idea that ambiguous treaty provisions