Question:
Elmer Francis Layden (May 4, 1903 - June 30, 1973) was an American football player, coach, college athletics administrator, and professional sports executive. He played college football at the University of Notre Dame where he starred at fullback as a member of the legendary "Four Horsemen" backfield. Layden played professionally in the original AFL in 1925 and 1926 with three different clubs, the Hartford Blues, the Brooklyn Horsemen, and the Rock Island Independents. He began his coaching career during the same two seasons at Columbia College in Dubuque, Iowa, now known as Loras College.
In 1941, the National Football League franchise owners voted to change the league's constitution in an attempt to bring all professional football leagues under the authority of one commissioner, who would have similar powers to that of Commissioner of Baseball Kenesaw Mountain Landis. Chicago Tribune journalist Arch Ward was offered the position of commissioner, but he turned it down and suggested Elmer Layden for the position.  Layden was appointed commissioner in February 1941. His appointment was not voted on by the entire league, which upset owners Alexis Thompson, Bert Bell, and Dan Topping. Chicago Bears owner George Halas contended that Layden's hiring was legal because it had been agreed upon by a majority of owners. Layden was signed to a five-year contract with an annual salary of $20,000.  In five years as Commissioner, Layden saw the NFL through the World War II years, in which teams had to use many men of inferior abilities as replacements while most of the regulars were fighting in the war (as did Major League Baseball). During this period a few teams temporarily merged due to lack of manpower, most notably the Pittsburgh Steelers with the Philadelphia Eagles (who were nicknamed the Steagles). The Cleveland Rams ceased operations for the 1943 season.  As NFL commissioner, Layden had once conducted an investigation into a betting scam, without advising the owners, which did not reveal any conspiracy.  Layden's tenure as NFL commissioner came to an end in January 1946. After Brooklyn owner Dan Topping withdrew his team from the league to join the new All-America Football Conference, the remaining owners agreed not to renew Layden's contract, feeling that he was too much of a gentleman and not forceful enough. Layden was succeeded by Bert Bell.
Answer this question using a quote from the text above:

How much did he earn as commissioner?

Answer:
Layden was signed to a five-year contract with an annual salary of $20,000.

input: Julia Stephen fell ill with influenza in February 1895, and never properly recovered, dying on 5 May, when Virginia was only 13. This was a pivotal moment in her life and the beginning of her struggles with mental illness. Essentially, her life had fallen apart. The Duckworths were travelling abroad at the time of their mother's death, and Stella returned immediately to take charge and assume her role. That summer, rather than return to the memories of St Ives, the Stephens went to Freshwater, Isle of Wight, where a number of their mother's family lived. It was there that Virginia had the first of her many nervous breakdowns, and Vanessa was forced to assume some of her mother's role in caring for Virginia's mental state. Stella became engaged to Jack Hills the following year and they were married on 10 April 1897, making Virginia even more dependent on her older sister.  George Duckworth also assumed some of their mother's role, taking upon himself the task of bringing them out into society. First Vanessa, then Virginia, in both cases an equal disaster, for it was not a rite of passage which resonated with either girl and attracted a scathing critique by Virgina regarding the conventional expectations of young upper class women "Society in those days was a perfectly competent, perfectly complacent, ruthless machine. A girl had no chance against its fangs. No other desires - say to paint, or to write - could be taken seriously". Rather her priorities were to escape from the Victorian conventionality of the downstairs drawing room to a "room of one's own" to pursue her writing aspirations. She would revisit this criticism in her depiction of Mrs Ramsay stating the duties of a Victorian mother in To the Lighthouse "an unmarried woman has missed the best of life".  The death of Stella Duckworth, her pregnant surrogate mother, on 19 July 1897, after a long illness, was a further blow to Virginia's sense of self, and the family dynamics. Woolf described the period following the death of both her mother and Stella as "1897-1904 -- the seven unhappy years", referring to "the lash of a random unheeding flail that pointlessly and brutally killed the two people who should, normally and naturally, have made those years, not perhaps happy but normal and natural". In April 1902 their father became ill, and although he underwent surgery later that year he never fully recovered, dying on 22 February 1904. Virginia's father's death precipitated a further breakdown. Later, Virginia would describe this time as one in which she was dealt successive blows as a "broken chrysalis" with wings still creased. Chrysalis occurs many times in Woolf's writing but the "broken chrysalis" was an image that became a metaphor for those exploring the relationship between Woolf and grief. At his death, Leslie Stephen's net worth was PS15,715 6s. 6d. (probate 23 March 1904)

Answer this question "did any more tragedies happen?"
output: Virginia would describe this time as one in which she was dealt successive blows as a "broken chrysalis" with wings still creased.

Answer the question at the end by quoting:

The Seneca are a group of indigenous Iroquoian-speaking people native to North America who historically lived south of Lake Ontario. They were the nation located farthest to the west within the Six Nations or Iroquois League (Haudenosaunee) in New York before the American Revolution. In the 21st century, more than 10,000 Seneca live in the United States, which has three federally recognized Seneca tribes. Two are in New York: the Seneca Nation of New York, with two reservations in western New York near Buffalo; and the Tonawanda Band of Seneca Native Americans.
On August 25, 1993, the Seneca filed suit in United States District Court to begin an action to reclaim land allegedly taken from it by New York without having gained required approval of the treaty by the United States Senate. Only the US government constitutionally has power to make treaties with the Native American nations. The lands consisted of Grand Island and several smaller islands in the Niagara River. In November 1993, the Tonawanda Band of Seneca Indians moved to join the claim as a plaintiff; it was granted standing as a plaintiff.  In 1998, the United States intervened in the lawsuits on behalf of the plaintiffs in the claim. This was to allow the claim to proceed against New York; the state had asserted that it was immune from suit under the Eleventh Amendment to the United States Constitution. After extensive negotiations and pre-trial procedures, all parties to the claim moved for judgment as a matter of law.  By decision and order dated June 21, 2002, the trial court held that the Seneca ceded the subject lands to Great Britain in the 1764 treaties of peace after the French and Indian War (Seven Years' War). Thus the disputed lands were no longer owned by the Seneca at the time of the 1794 Treaty of Canandaigua. The court found that the state of New York's "purchase" of the lands from the Seneca in 1815 was intended to avoid conflict with them, but the state already owned it by virtue of Great Britain's defeat in the Revolution and cession of its lands to the United States (and by default to the states in which the colonial lands were located.  The Seneca appealed this decision. The United States Court of Appeals for the Second Circuit affirmed the trial court's decision on September 9, 2004. The Seneca sought review of this decision by the US Supreme Court, which on June 5, 2006, announced that it would decline to hear the case, leaving the lower court rulings in place.

Has there been protests or any activism around this claim?