25 U.S.C. § 194

In all trials about the right of property in which an Indian may be a party on one side, and a white person on the other, the burden of proof shall rest upon the white person, whenever the Indian shall make out a presumption of title in himself from the fact of previous possession or ownership.

(R.S. §2126.)

R.S. §2126 derived from act June 30, 1834, ch. 161, §22, 4 Stat. 733.