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17 tension between the power of Congress over Indian affairs and the special obligations owed Indians by Congress that constrain the exercise of that power.46 The power of the federal government over Indian affairs is usually described as "plenary," meaning full or complete.47 That power is so great that it even allows Congress to abrogate a treaty obligation against the will of the Indians involved.46 Thus Congress could, other things being equal, quantify a tribe's Winters rights without that tribe's consent. But the power of Congress over Indians, though full and complete, is not absolute. In United States v. Dioo. the Supreme Court held in 1985 that for Congress to abrogate a treaty provision, its intent to do so must be "clear and plain."49 The Court went on to specify that ''what is essential is clear evidence that Congress actually considered the conflict between its intended action on the one hand and Indian treaty rights on the other, and chose to resolve that conflict by abrogating 46~ F. Cohen, ~ note 4 at 207. The federal government is the source of authority over Indians, not the states. ~ C. Wilkinson, Indians. Time. and the Law 24 (1987), citing lohnson v. M'Intosh. 21, U.S. (8 Wheat.) 543 (1832), Cherokee Nation v. Geor~a. 30 U.S. (5 Pet) 1 (1831), and Worcester v. Geori:ia 31 U.S. (6 Pet.) 515 (1932). See also Getches and Wilkinson,.mm note 3 at 161. 47United States v. Kagama is usually cited as the primary source of the plenary power doctrine. 118 U.S. 375 (1885). ~ F. Cohen, .sJ.U2m note 4 at 207-212. 46Lone Wolf v. Hitchcock. 187 U.S. 553 (1903). 'The power exists to abrogate the provisions of an Indian treaty, though presumably such power will be exercised only when circumstances arise which will not only justify the government disregarding the stipulations of the treaty, but may demand, in the interest of the country and the Indians themselves that it should do so." Id. at 566. 49U S. v. Dion. 476 U.S. 734 at 738 (1985).