This is close to being a banking system, and the accounts are similar to savings accounts that earn interest. BIA avoids the word "bank," but since some Indian reservations are located far from banking centers, money is often allowed to accumulate in these accounts for safekeeping and to earn interest.
BIA calls this the IIM (Individual Indian Money) system. Indians who live on reservations all know what "IIM" stands for, so by learning about this you will increase your knowledge about the lives of today's Indians.
IIM is not taxpayer money; it is the personal income of Indian people held in trust. Most of the accounts are for individuals, but there are also large accounts for tribes and tribal groups.
The reason for IIM accounts dates back to when Indians were mislabeled as incompetent, thus enabling BIA to manage their money for them. Using this theory, BIA could control all personal and tribal income as one more way to control Indians, and BIA supervisors had the opportunity to pick the pockets of Indians. That should come as no surprise. Historical accounts are filled with stories about petty theft and grand larceny directed against Indians by those entrusted with their care.
Traditional Indians believed in sharing with their greater family, the tribe. No individual should be too rich or too poor. It was a grand gesture (and to some extent still is) among Indians to have a "giveaway." If one tribal member managed to accumulate more wealth than others, he/she would have a public party and give the excess to tribal neighbors. Our transplanted European culture found this to be stupid, dirty and anti-capitalistic, and it was discouraged. In Canada, for instance, the potlatch was declared illegal.
BIA disapproved of this. Part of "civilizing" Indians was to teach greed as a virtue. After all, it was a sign of capitalism. Indians were forced to conform to the white concept of values. Greed is good and sharing is stupid according to the whiteman's rules. The Indian ethic of sharing had no value.
The trust funds provided a source for the embezzlement of funds by BIA officials. Autocratic control, little or no accountability and immunity from lawsuits makes for easy picking.
Over the years, BIA reduced it's function of control over the use of these funds. The Agency Superintendent still serves as guardian in some cases (for minor children, adults in mental institutions, etc.) but in most cases money collected for an account holder (or what's left of it) is paid out to the account holder after a few days.
There are computer terminals at each reservation in the Agency offices. BIA does the billing for land rents and similar transactions. Money is received at the Agency office by a federal cashier, and entries are made on the computer terminal to credit the accounts of the owners. A typical transaction would be grazing fees received from a non-Indian who leases Indian land.
The computer terminals are connected by direct wire to the Area Office (in this case, Billings) where the IIM accounts are maintained. The money (mostly checks) is mailed to Billings, where work is done to deposit the money in a federal bank account.
You might hope for a tight connection between the entries made by wire from the Agency offices, and the actual flow of money into the federal bank account. There is not, there is only a very fuzzy connection, which is a terribly serious problem.
It's possible to make entries at the Agency without any cash reaching Billings. It's also possible for cash collections to arrive in Billings, without any entry to credit the individual accounts. I am the first CPA (other than the rare federal auditor) to examine this in detail, and I tell you that's what I found.
There is a near complete lack of control and accountability. One of my first assignments with BIA was to study the IIM accounting system. My job description said I was to "review, report and then recommend" any improvements needed in the system. This is a very standard assignment for an accountant or auditor, and with thirty years experience in corporate and public accounting and auditing, I was qualified to do the work.
You're going to keep hearing the word "reconciliation" when we talk about this, so it's important to understand what that means in this particular context. The term is very broad, so it must be defined to fit the situation at BIA.
Let's assume you have a checking account. Each time you make a deposit or write a check, you add or subtract from your old balance to arrive at a new balance on your check stub or check register. Each month you receive a bank statement in the mail, and you compare your balance with what the bank shows.
Often the amounts don't agree, so you look for bank service charges, checks outstanding, and so forth. This is what people think of as reconciling, and it's necessary for catching errors.
For household checking accounts, the mysteries usually aren't difficult, so you can do the job yourself, or a trip to the bank solves any remaining problems. For a large commercial account with millions of dollars and thousands of transactions, the job is more difficult, but trained bookkeepers or accountants can solve the problems. For large accounts, reconciling is essential.
For BIA IIM accounts, there are two things to be reconciled. One is the individual's account, which is maintained on the computer in Billings. That is the computer that the Agencies are connected to by wire. The accounts are totaled at the end of the month and that's the equivalent of your household checking account balance.
The thing to match is the total shown on the bank statement. The Billings office does not see the bank statement since it's kept by another BIA office (in Albuquerque, New Mexico). Billings does get a copy of the Albuquerque bank records, which serves the purpose of a bank statement. (For the technical reader, it's a copy of the general ledger account showing cash in the bank).
So far there's nothing evil in this. Billings has the information it needs to reconcile the IIM accounts. The problem is, I found that Billings does not reconcile the accounts, and had never even compared the two balances.
At first thought that sounds more sloppy than evil. The problem is that it's somebody else's money, BIA is supposed to provide a high level of care for it, and there are hundreds of millions of dollars missing from the accounts of people who live in poverty.
BIA has such sloppy records that there is no way to find out what happened. The money is gone. Where it went is unknown, since nobody at BIA is willing to look. Old records have conveniently been destroyed, making it impossible to reconstruct past transactions.
It appears to me, after examining the situation in depth until I was stopped short, that this is the result of decades of unrestricted theft by BIA personnel. But what about our national concept of assuming innocence until guilt is proven?
Pretend for a minute that you find yourself relying on a trustee to hold your money, and you have some idea about how much he is receiving each year. Year after year he pays out less than received, and he refuses to give you any reports about your balances. Authoritative experts report again and again that your trustee does sloppy work and refuses to make any improvements in his system. Years go by, always the same, and you are always missing money, lots of money. I suggest that at some point in time, based on these facts, the burden of proof shifts to discredit the person holding the cash. Your suspicions are based on reason, and it is the trustee who needs to prove his honesty.
Billings is not the only BIA Area Office where this has happened, although that would be bad enough. The same thing has happened in every BIA Area Office. The Indian's trust accounts have not been handled in a trustworthy fashion, and the taxpayers will have to foot the bill to replace the hundreds of millions of dollars that are missing.
Let's not play games, to be correct about it, the only logical conclusion is that the money has been stolen. There might not be a legal obligation, but there is an ethical and moral obligation for BIA to return the missing money. That is where this reaches into your pocket.
At Billings, my initial report was that the missing amount was $7.5 million dollars, which was the NET of shortages and excesses. The gross amount is much greater that that, and what happened to the money will never be known. It is a fact that the money is missing, and the only possible explanation is grand larceny. After the first hundred years or so of a continuing problem, I believe the burden of proof must shift to the party whose hands are in the cash box, and that party is BIA.
To prepare for my audit assignment I looked for any earlier studies about the IIM system. I found the following:
EARLIER REPORTS:
The General Accounting Office (GAO), an auditing arm of Congress, had issued a report in 1982 titled REPORT TO THE CONGRESS, signed by the Comptroller General, dated September 8, 1982.
Page 17 of that report stated that BIA's trust fund accounting was not reliable. Local offices did not complete required reconciliations, and the accounts were out of balance by millions of dollars. The situation had not improved since a previous study in 1968. (Note that they said "out of balance," not "missing money," as I would say later on.)
On page 29, it strongly recommended that reconciliations should be done, and on page 33 BIA said it would "require that these reconciliations be done."
During my work I discovered that BIA's response to the earlier audit was false. There had been no changes or improvements since 1968, a period of eighteen years. BIA's response was an empty promise. BIA knew the promise was empty when it made it.
To "require that these reconciliations be done" means that BIA would issue a "directive" or instruction. There are several catches that make a directive like this deceptive.
First, the system is so poorly designed that without improving it, reconciliations are impossible. Note that the directive does not even mention improving the system.
BIA does not have the trained people on its staff who could perform the reconciliations, even if the system was improved.
BIA's directives are not addressed to a particular person or office with the authority and responsibility to accomplish the task, and the directives are not enforced. BIA's promise was in 1982, and yet in 1994 the accounts still are not being reconciled.
The accounts in Billings were not being reconciled, and in the memory of employees, they never had been. I learned that from my own audit work. In continuing my search for earlier studies, I found a report issued by the Interior Department's Office of Inspector General.
INSPECTOR GENERAL REPORT - SEPT. 1985:
On page 13, their study of another area office showed the cash accounts at that office short by forty two million dollars.
Later, an informant that I believe to be reliable told me that the other office had a fictitious account under the name of R.L. Larson. The Larson account was used to skim cash from Indians, for BIA expenses and for the personal pockets of BIA employees. I do not have personal knowledge of this but it seems most likely. Cash does not evaporate, and Larson is a cute name for larceny. That word "short" s mine, the previous audits are never that definite, and never speak of grand larceny. I was to be the first person to call itwhat it is, larceny of the poor.
On page 14 of the report, OIG auditors made a grave error. They said:
.".. all agency accounts for ... Billings ... had been reconciled. We concluded that these reconciliations were being accomplished timely and accurately ..."
That quotation is very important, and I want you to remember it; I will refer to it again. In my reports about the IIM system I said the OIG audit was deceptive, which is a simple fact, and in a later letter to me (dated 12/15/87) OIG auditors admitted that in their earlier report (stating reconciliations were being accomplished) "we did not verify ...." In straight language, that means they did not bother tolook. That letter from the Inspector General is in my files, copies have gone to Congress, etc., so it's a public record, not some unsupported claim.
BIA referred to my report (that the OIG audit was wrong) as "frivolous and unwarranted," and in my boss, Bill Benjamin’s, letter of dismissal my report about OIG's error was used as grounds for firing me. Benjamin knew at the time that the OIG audit was wrong. I told him about it several times, and gave him clear proof and written evidence to show that the accounts were not reconciled, which Benjamin fully understood.
That's important. I spent hours discussing this with Benjamin, and he understood the accounts were not reconciled, and he knew this was important. He knew my report was correct but still used it as grounds to fire me for insubordination.
Long after being fired, I received a letter from James R. Richards, Inspector General, dated April 19, 1988 in answer to repeated questions and letters from me and pressure from a congressional representative. Referring to the 1985 OIG audit, the Inspector General's letter states:
"we have concluded that [the statement in] our prior audit was not factual."
The final paragraph in Mr. Richards letter reads:
.".. we agree that ... our prior audit ... was in error and ... may have misled the Bureau of Indian Affairs. We regret if this ... in any way contributed to your problems with the Bureau."
What a joke!. Contributed to my problem? It was used as a false ground to fire me, and at the time I was fired Benjamin knew it was false. I was financially ruined over this "error," one hell of a price to pay for preparing an honest report.
I spent several months reviewing IIM, so it's necessary to give you a summary. After researching earlier studies, I gathered all the information available on the computer system and programs, and learned to use the computer to inquire about accounts. I spoke to the programmers and computer operators to learn what they did, and I studied the information produced by the computers.
Much time was spent with Donna Boyer, the head of Billings IIM clerical work. One of her main jobs was to prepare what was (in error) called a reconciliation. Whoever designed her job didn't understand what a reconciliation was, because what she produced was not a reconciliation at all. She was loyally and efficiently doing her assigned work, but it had no connection to reconciling, just unnecessary wheel spinning.
The individual accounts are kept on a computer in Billings, controlled by that direct wire from the Agencies. The cash is deposited in a federal bank account in Albuquerque, New Mexico. This will start to make sense to you in a minute or two.
It is obvious that the two things should agree. The total in the depositors accounts should be the same as the amount of cash in the bank. However, I soon discovered that more cash was coming in than was being credited to the depositors accounts.
The idea of matching the two, or reconciling, is something that commercial banks, savings and loan institutions and credit unions do every day. At banks reconciling is sometimes just called balancing, or balancing the books.
Banks hire accountants and auditors of their own. Each state employs auditors and so do the Federal agencies that inspect banks. At the Billings Area Office, there is one person with final authority over cash controls and bank reconciliations. It is a man we will get to know better, Bill Benjamin, my boss at BIA.
The IIM account balances in Billings amount to around fifty million dollars, which makes BIA one of the largest "banks" in Billings.
If you assume that BIA employs accountants and auditors, like the banks do to watch over their money, then you are wrong. I was the first accountant employed in Billings in anyone's memory, and they had never employed an auditor. In fact, BIA has very few accountants, and among it's thirty thousand employees, not a single auditor.
If you take a course in accounting or in business law, you will find that when it comes to a trust fund or trust accounting, high standards are required. If you are paid to take care of somebody else's property, your work should be above suspicion. The words in Black's Law Dictionary that best describe the duties of a trustee are: fiduciary, obligation, confidence and faithfully.
The rule handed down to us from English law is that a trustee is liable for providing a "high degree" of responsible care. If a (nongovernmental) trustee fails to do that, he or she is liable for the missing money, for fines and for a prison sentence. At the very least, BIA has an ethical and moral obligation to meet the standards that apply to trustees.
In an earlier chapter, we quoted BIA's words that part of it's mission was to "fulfill and execute the Federal Government's trust obligations to American Indians." Now we see that BIA does not provide good trust services. BIA seldom tells the truth about itself or about Indians, and here you have a concrete example of that.
So, what did I find? I had asked Donna to compare the two totals; the individual accounts with the balance in the bank. She found the individual accounts were short by more than six million dollars. She was close, and when I did my (more exacting) work I found that as of 2/28/86 the exact net difference was $7,584,313.82. There was more cash in the bank than had been credited to the accounts of the Indian owners.
Most accountants would tell you - and I will tell you here - that if bank records are rife with errors, never balanced and out of control, it is wise to think about embezzlement and stealing. I did not find it, I was stopped; fired by Benjamin before I could look any further. Accountants also know that in a situation like this, there could be both positives and negatives (shortages and excesses) within some net balance. My report only described the NET difference in the balances.
There is room to play with words here. From the viewpoint of the Indians the accounts are short. The money that was collected was not credited to their accounts, so there is no way they could draw it out.
BIA will play with words if it is to their advantage. It took BIA several YEARS before they agreed that the facts I reported were correct, and they still imply that it is not a serious problem.
All my reports on this give an exact date and amount with good reason. One way BIA handles problems is to generalize them, such as to respond that there may have been some minor inaccuracy at some point in time, but that generally there is no problem. My specific complaint about a specific problem at a specific date prevents BIA from doing an end run.
Now, if you had a bank where the deposits were not added to your account, what would you call it? Most people would say they were robbed, most would call the police. You would certainly look at your bank statements carefully, but then BIA does not send statements out very often, and in some cases almost never.
An OIG audit of the IIM accounts at the Fort Peck, Montana, BIA Agency office found in 1985 that "statements have not been distributed since 1979." (Audit W-IA-BIA-18-84).
That's six years with no detailed accounting to the account holders. Would you like to have BIA take charge of your money and never give you a bank statement?
After leaving BIA, a tribal government in another state phoned me. I will be vague about identities here to protect them from reprisal. A top administrator of that tribe told me:
"BIA is robbing us, and won't let us have a record of our account. Without access to our own money to operate tribal government, our tribe is failing."
Let me remind you - this is not Federal money, it is the tribe's earnings from property the tribe owns. BIA was holding back the tribe's own money. BIA's action did not match it's mission statement to "strengthen tribal capacity to govern." In reality, it was destroying the tribal government's capacity to operate by leaving it with no cash. This was not the Crow Tribe, but you will see elsewhere in this book that the same thing was done in a vindictive fashion to the Crow Government.
I believed the person who phoned me, but there was nothing I could do, and I had no answer. BIA's trap is effective. There are no police to call, our legal system makes BIA exempt from lawsuits, and the FBI does not investigate when a federal agency harms American citizens, at least not if the citizens are Indian.
In Billings, I reported my findings to Bill Benjamin including a copy of Donna Boyer's findings on April 17, 1986, and gave him a more detailed report on April 29. Nothing was done. After urging him verbally several times, and waiting over two months, I wrote directly to the Assistant Secretary of the Interior (for Indian Affairs) on July 9th. There was no response from Ross Swimmer. On July 23, I made a formal report at a committee meeting. There were several reasons to report this, in addition to a general suspicion of fraud and grand theft:
1). Job assignment, as described earlier.
2). Job description, to use professional judgment.
3). CPA professional ethics, and the basic
requirement of full disclosure.
4). Federal laws about waste, fraud and abuse.
5). My Federal oath of office.
6). Past military service oath.
7). Congressional Code of Ethics for Government Service.
Article 9 states "expose corruption
wherever discovered."
8). Legal requirements of trusteeship.
9). Dictates of religion and conscience.
During my follow-up after being fired, I wrote to Montana's Senator Max Baucus. He asked for a response from BIA. Here is what BIA's Director ofAdministration, Nancy Garrett, had to say about the problem in her letter of 5/29/87 responding to Senator Baucus:
"In performing its trust responsibilities, the Bureau's intent is to achieve the highest degree of accuracy and quality possible. As with any large accounting system which carries data for a high volume of ... accounts, errors may occur. However, these errors are detected and corrected through the account reconciliation process which is required to be performed on a monthly basis."
Garrett's letter is not just worthless hot-air, it is deceptive, and she had to know that when she wrote it. Her words "required to be performed" are unrelated to the factual situation; her response amounted to a lie. Garrett wrote a similar letter on 07/02/87 with almost identical wording to U. S. Representative Ron Marlenee.
As of 1994, the reconciliations are still not done and the missing millions are not accounted for.
In my follow-up after being fired by BIA, I was assisted by Montana's Senator Max Baucus who asked BIA to respond to written questions from me. The question about IIM was "do you agree with the factual situation." It took BIA five months to answer that, but here is the response of William Ragsdale (BIA’s chief career employee) dated December 17, 1987.
"Yes, we agree that there was a difference of $7,584,313. [at 2/28/86]."
Ragsdale's letter said there would be a training program to "address the problem."
OIG audit (No. 88-116), which resulted from my "allegations," as BIA always puts it, was finally issued in September, 1988. The audit, rounded to the nearest dollar, stated that the unaccounted for difference was $7,584,314. It went on to say:
"the Area Office did not know whether the 39,000 ... accounts valued at $51. million were correctly stated."
In ordinary language that means the records are not right and the system is out of control. The $7.5 million I reported was a net difference. When the accounts (within that net) are segregated by type, the individuals accounts (just one part of IIM) are short by $27. million dollars, according to OIG's own figures. The gross differences that I add up from OIG' figures are over 60 million dollars. So, although the NAME of this issue at the Billings Area Office relates to $7.5 million, the measure of it is around $60. million at just this one location. The situation for America’s Indians is a real mess.
After my many complaints, the international accounting firm of Arthur Andersen & Co. was retained by BIA (after a shove from various Senators) to do certain audit work on these trust funds. Using the Freedom of Information Act, I obtained hundreds of pages of audit reports, some of which are referred to in this book.
Here are some of the words from one of those pages, which I will enclose as Appendix 2. The date was February 20, 1989, but I believe it is typical of the continuing situation. It is a report about replies received from IIM account holders who were asked to respond if their IIM balances were in error:
"The majority of the negative comments are from the Phoenix and Billings areas. ... The most common complaints are (in order of occurrence) ..
1.) Haven't received checks listed on statements.
2.)... in many instances, had never seen a statement prior to this mailing.
3.) Have no knowledge of even the existence of the accounts confirmed."
All BIA Area offices have a similar situation. The total cost for BIA to straighten out this mess, replacing cash missing from the accounts of Indians, based on what I know, could easily reach a billion dollars (not counting interest).
You can bet that BIA will say shortages are offset by overages, to make this issue of minor importance. I won't buy that for a minute, because it's dead wrong.
The benefit of any doubt (remember the high level of care required by trustees) does not belong to the trustee, it belongs to the beneficiaries. That is the rule we get from our system of law, and here we are dealing with oppressed human beings, not just "accounts."
The OIG reports lean in favor of BIA, not the holders of the Indian trust accounts. That is bias rather than independence on the part of the auditor. Let's see how the OIG report treats the discrepancies that I described while employed by BIA:
"We found that this difference ... resulted primarily from computer system design and reconciliation procedure deficiencies that existed for several years. ... our adjustments tend to explain all but $374,000. of the $7.6 million net difference ... In theory, these adjustments should not have any effect on the underlying individual and tribal account balances ..."
So, OIG makes it a relatively small matter, and "tends to explain" that the problem should have no effect on the accounts. Yet on the same page they make the other statement (quoted earlier) that BIA "did not know whether the 39,000 ... accounts were correctly stated."
I tend to think they are lying through their teeth, and OIG has a forked tongue.
Just who pocketed the roughly 60 million dollars that was skimmed off the Billings Area trust accounts over the years? According to OIG, apparently the computer did it.
If I call it $60. million, and the Inspector General calls it $374,000., who is right? To me the OIG audit is a soft (kissing-up) report about a real and massive problem; a sad example of "no fault government" where nobody is responsible for problems and the problems are treated lightly. I suggest that the federal courts should decide the issue, and there should be a jury to determine the amount including interest and damages. OIG's people who do the actual auditing may be basically honest, but their final report is written or edited by those who they make things look as good as possible to keep their jobs.
Another potential loose-end concerns the accounting work done at Albuquerque. Their reports (general ledger) are supposed to agree with the cash in the bank, but I had no way to test whether or not their records are accurate. From what we've seen of BIA's accounting, I believe that the Albuquerque reports should be audited by independent CPAs.
As a matter of fact, that has happened, I believe at least in part because of pressure from me. Following the investigation of BIA by the Senate Select Committee on Indian Affairs, BIA was required to hire the CPA firm of Arthur Andersen & Co. to audit trust accounting and certain irrigation operations.
It also just so happens that my first job out of college was with Arthur Andersen. My first thought about this development was hopeful, because I have a warm place in my heart (and a lot of respect) for AA & Co., as it is called, which is now one of the world's largest CPA firm.
Times have changed, the great CPA firms no longer have untarnished reputations, but have Washington DC offices which are cozy with federal politicians. The major CPA firms are hard to distinguish from other "consulting" firms that buy favors and remain kissykissy with politicians. The national CPA firms pay large sums into congressional campaign funds, no different than the other "consultants," and they expect a profitable return for their money, such as million dollar audit contracts. They know where the money comes from, and don't bite the hand that feeds them. So - who do you trust.
I trust that the dollar amounts in Arthur Andersen's audit reports of BIA trust accounts are as accurate as possible, although I don't necessarily agree with the opinions and reasoning shown in their reports. Let's take a look at some of the recent audit reports, obtained by me through the Freedom of Information Act.
In an audit report dated January 31, 1991, AA & Co. reported that:
"Summaries of daily deposits prepared by field offices do not agree and are not reconciled to the general ledger.".. and "we found a lack of overall coordination and standardization ..."
In another report (as of September 30, 1990), Arthur Andersen & Co., reported that the Billings area office's unaccounted for trust account balance was $6,470,098. (net) which is not much of an improvement from the $7.5 million net shortage I reported in 1986.
This outside audit by AA & Co. puts the lie to OIG's bald-faced claim that all but $374,000. was accounted for.
So, with three different figures, who can you believe? I was there, and I suggest that either the AA & Co. amount, or mine, is close enough as a NET difference, although NET doesn't mean much compared to the GROSS shortage to taxpayers and Indians in these "trust" funds controlled by BIA.
The real difference between me and AA & Co., my years-ago employer, is that I was getting paid thirty-one thousand dollars a year, while AA & Co. is collecting about a million dollars a year in audit fees out of the Indian budget. I was financially ruined because of my report, while AA & Co. is well paid. Members of congress can count on contributions into their campaign funds from the nations large auditing firms who kiss-up to them.
How do you measure the total dollar amount of this problem? There is no exact way, so an estimate is the best I can do. I call it about $60 million at the Billings Area office, and then multiply that by ten since the Billings Area represents about a tenth of the whole.
That makes $600 million before interest. The problem has continued for one hundred fifty years, so interest must be added. At a very modest minimum, that should double or triple the amount. Then add the cost for more audits, courts and attorneys. I estimate that stealing from Indians will cost our taxpayers not less than twobillion dollars in total. A newspaper article by columnist Jack Anderson in August, 1993, called the problem a "Fiasco.", and he is absolutely correct.
A repeated pattern begins to emerge, and you can see how BIA handles whistleblowers. First the claims are treated as false, and if they conflict with BIA's self image, whistleblowers are called disrespectful of existing authority, which is insubordination.
If the claims are proven accurate, then they are an unimportant trifle, nothing new. Surely BIA can't be accused of suppressing information if that information is neither original nor important.
If the claims prove to be both original and important, still they were disrespectful and their suppression by BIA was an innocent error, not worth correcting. After all, the whistleblower has an opportunity to dispute the matter through specific government channels, so we must wait for that result.
If not much time has passed, reference is made to the appeals procedure, and BIA will tell you that procedures must be followed. After years are spent on fruitless appeals, then the issue is so old that it no longer is important. Yes, the people who suppressed honesty have been promoted, but after all, they are worthy and loyal employees and anyone can make an honest mistake. This pattern is used again and again to defeat honesty and to hide massive fraud.
Now it is time to learn about Docket #184, and see what that strange title reveals about Bill Benjamin and BIA. We'll start hearing about Julie Matt, a Northern Cheyenne woman whose life was changed when she discovered problems with the way Bill Benjamin handled Docket #184.
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