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61COVID-19 and First Nations’ Responses travel to these First Nations communities to stock up on cigarettes. Simultaneously, there was an increase in online racism against First Nations communities that issued temporary closures.33 To mitigate against the risk of infection within the Nation, some First Nations communities are limiting access to the reserve to resi- dents only (and in some cases excluding non-resident citizens of the nation). This is in step with, for example, a province closing its bor- ders to others (as Quebec has done, for example) or Canada closing the border to the United States to slow the spread of COVID-19. As we write, warmer weather approaches and many First Nations in Ontario are discouraging non-resident cottagers from travelling to their com- munities due to the increased potential for the spread of COVID-19. Another unique constitutional question arises in this context: can non- resident mobility rights under section 6 of the Charter be restricted by the application of First Nations jurisdiction and the protection of “rights or freedoms that pertain to the aboriginal peoples of Canada” against charter claims?34 There have been tensions between First Nations that have exer- cised their jurisdictional assertion to protect the health of their people and non-resident cottagers. Cottage leases located on reserves are sub- ject to various laws, including the Indian Act35 and the First Nation Lands Management  Act.36 Generally, reserve lands cannot be privately owned, though they can be leased to non-residents and are often used for non- resident cottagers. First Nations retain the right as to whether or not to renew a cottage lease by way of statute37 or inherent right.38 A different question arises when First Nations communities wish to exercise pub- lic health authorities to prevent a non-resident cottager from entering their community, where to do so would put the community at risk. 33. Kim Uyede-Kai, “COIVD-19 and the Racism Pandemic We Need to Talk About” (April 2020), online: Shining  Waters  Regional  Council  <https://shiningwatersregion- alcouncil.ca/wp-content/uploads/2020/04/COVID-19-and-Racism-Pandemic- SWRC-revised.pdf>; Roberta K Timothy, “Coronavirus Is Not the ‘Great Equalizer’—Race Matters: U of T Expert”, U of T News (8 April 2020), online: <https://www.utoronto.ca/news/coronavirus-not-great-equalizer-race-matters- u-t-expert>. 34. Canadian  Charter  of  Rights  and  Freedoms, s 25, Part I of the Constitution  Act,  1982, being Schedule B to the Canada  Act  1982 (UK), 1982, c 11. 35. Indian Act, RSC, 1985, c I-5, ss 38 and 53. 36. First  Nation  Land  Management  Act, SC 1999, c 24, s 18(1)(b). 37. Williston  v  Canada  (Minister  of  Indian  Affairs  and  Northern  Development), 2005 FC 829. 38. Devil’s  Gap  Cottagers  (1982)  Ltd  v  Rat  Portage  Band  No  38B,  2008 FC 812.