Tough one. passage summary:
1903: Supreme Court (SC) ruled against native americans in a case
Some guy named Blue "properly" (author's opinion) notes that the SC basically said the US Gov't has power over the tribes. But he "fails" (author's opinion) to note a bigger impact of the decision: afterwards, gov't stopped making agreements with the tribes and just did what it wanted.
Other people thought this (gov't just doing what it wanted) happened in 1871, but it didn't (author's opinion). Gov't kept negotiating agreements it treated as legislation instead of treaties. (Implication: before 1871, gov't negotiated treaties; after 1871, gov't negotiated agreements to be passed as legislation)
After the 1903 case, the gov't stopped even negotiating things as agreements and just did what it wanted.
Choice C says that the gov't no longer needed to conclude a formal agreement, which implies that the gov't did have to conclude a formal agreement before the 1903 case. But look at the last line of the passage: "the government did away with what had increasingly become the empty formality of obtaining tribal consent." That means they didn't HAVE to obtain agreement by law or anything - they did it because they were being polite or something like that.
Now go back up to lines 9 and 10, where it talks about "the Court's assertion of a virtually unlimited unilateral power of Congress over Native American affairs." That means the Court decided that Congress could do whatever it wanted and the tribes couldn't do anything about it (at least, relative to challenging Congress via the Supreme Court).
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