The 1864 Act, also know as the "Four Reservations Act,” specifically stated that no more than four Indian reservations could be established within the State of California. This statutory limitation to four reservations within California was confirmed by the United States Supreme Court in the case of Mattz v. Arnett, 412 U. S. 481, 489 (1973). Thus, there could be no further reservations within California in the absence of specific Congressional authorization. While there have been some private bills establishing reservations for some California tribes, the only significant exception was the Mission Indians Relief Act of January 12, 1891, 26 Stat. 712, which provided for the establishment of a number of reservations for Mission Indian residing in Southern California.