The relationship between the United States and Native America has evolved over time from warfare and paternalism to recognition of tribes as sovereign governments. That has allowed tribal governments to exercise more control over energy and economic development on reservations including the opening of casinos through state compacts. Issues from the past still linger, though, as tribes fight for what they consider ancestral water rights in local negotiations which may required congressional funding to complete. While Congress and tribal governments work on health and education issues, perhaps the biggest piece of unfinished business is what has become known as the Cobell settlement. The case is named for Elouise Cobell, a member of the Blackfeet tribe, who sued in 1996 claiming the federal government had mismanaged the trust fund set up for individual tribal members' shares of royalty payments from development of natural resources on tribal lands. Cobell died in Oct. 2011. A negotiated settlement calls for $3.4 billion in payments to about 500,000 tribal members, but some tribes have objected to aspects of the settlement. The first of several complaints was heard by a U.S. Court of Appeals in February 2012.