The territorial courthouse was established under the Nonintercourse Act. Courts have considered and rejected several affirmative defenses to Nonintercourse Act suits. The Nonintercourse Act does not prohibit leases. On 30 March 1802, Congress passed the revised Indian Nonintercourse Act. As stated in "Narragansett", there are four elements to a Nonintercourse Act claim. Moreover, the New York courts' interpretation of the Nonintercourse Act is no longer good law. There, the plaintiffs challenged the Phelps and Gorham Purchase under the Nonintercourse Act. However, the Nonintercourse Act itself does not abrogate state sovereign immunity. The Nonintercourse Act of 1834 specifically prohibited White American intrusion into Indian territories. In several cases, Nonintercourse Act plaintiffs have satisfied one of these exceptions. The Nonintercourse Act of 1790 marked the beginning of the Trade and Industrial era.