Andrew Jackson had a reputation as a representative of the “common man” and the “Hero of New Orleans” for his battle victory there during the War of 1812. While not a popular man with many of his political and intellectual peers, including Alexis de Tocqueville, he found a contentious place among American historians for his treatment of Native Americans. As president, Jackson took a hard stance on the removal of Native Americans from the American South to lands west of the Mississippi River. Previous administrations had weakly supported both removal and civilize-and-integrate schemes, but Jackson and the U.S. Congress chose to pass the Indian Removal Act of 1830. The act authorized Jackson to negotiate directly with tribal leadership for the purchase of tribal lands in the East in exchange for land outside the existing borders of the United States, with the caveat that should the tribal leaders elect not to relocate, they must relinquish their sovereignty and obey the laws and norms of American society. After the Georgia Cherokees lost legal protections from white encroachment in Worcester v. Georgia in 1832, and hearing reports of the inhumane treatment of the Choctaw in their winter removal from the South, the Seminoles and Creek were beginning to have violent clashes with whites. Jackson saw an opportunity to attempt to avert an all-out war from raging in the American South.