Despite opposition from the Chickasaws, Congress incorporated the Atoka Agreement into the Curtis Act, which passed on June 28, 1898. This act authorized the federal government to allot Chickasaw lands even though the tribe owned those lands. In addition, it took away Chickasaw jurisdiction over Indian courts, gave the government control of the tribe’s schools and established a framework for the termination of the federal government’s recognition of Chickasaw’s rights to self-government. Despite setting that framework, Congress never terminated its recognition of the sovereign Chickasaw Nation, and instead continued such recognition as section 28 of the 1906 Act.
The Curtis Act also granted the Chickasaw freedmen 40-acre allotments. However, in 1902, the U.S. Supreme Court ruled that the freedmen were not entitled to citizenship in the Chickasaw Nation. The federal government reimbursed the Chickasaw tribal funds for land allotted to the freedmen. In 1907, the final Chickasaw Freedmen Role was adjusted to include 4,662 names.