United States v. Sioux Nation of Indians

Last updated

United States v. Sioux Nation of Indians
Seal of the United States Supreme Court.svg
Supreme Court of the United States
Argued March 24, 1980
Decided June 30, 1980
Full case nameUnited States v. Sioux Nation of Indians, et al.
Citations448 U.S. 371 ( more )
100 S. Ct. 2716; 65 L. Ed. 2d 844; 1980 U.S. LEXIS 147
Case history
PriorSioux Nation of Indians, et al. v. United States,601F.2d1157(Ct. Cl.1979).
Holding
1) The enactment by Congress of a law allowing the Sioux Nation to pursue a claim against the United States that had been previously adjudicated did not violate the doctrine of separation of powers, and 2) the taking of property that was set aside for the use of the tribe required just compensation, including interest.
Court membership
Chief Justice
Warren E. Burger
Associate Justices
William J. Brennan Jr.  · Potter Stewart
Byron White  · Thurgood Marshall
Harry Blackmun  · Lewis F. Powell Jr.
William Rehnquist  · John P. Stevens
Case opinions
MajorityBlackmun, joined by Burger, Brennan, Stewart, Marshall, Powell, Stevens; White (parts III, V only)
ConcurrenceWhite
DissentRehnquist
Laws applied
U.S. Const. amend. V; 15  Stat.   635

United States v. Sioux Nation of Indians, 448 U.S. 371 (1980), was a United States Supreme Court case in which the Court held that: 1) the enactment by Congress of a law allowing the Sioux Nation to pursue a claim against the United States that had been previously adjudicated did not violate the doctrine of separation of powers; and 2) the taking of property that was set aside for the use of the tribe required just compensation, including interest. The Sioux have not accepted the compensation awarded to them by this case, valued at over $1 billion as of 2018.

Contents

Facts of the case

The Treaty of Fort Laramie (1868) pledged that the Great Sioux Reservation, including the Black Hills, would be "set apart for the absolute and undisturbed use and occupation of the Indians." [1] By the terms of the treaty, cession of any part of the reservation required a new treaty executed and signed by at least three fourths of all the adult male Indians occupying the land. [2] The Sioux's right to hunt in some unceded territories were protected by the Fort Laramie Treaty as well. [3] The Fort Laramie Treaty ended Red Cloud's War, a series of military engagements in which the Sioux tribes, led by chief Red Cloud, fought to protect the integrity of earlier-recognized treaty lands from the incursion of white settlers. [4]

The 1868 treaty brought peace for a few years, but in 1874 an exploratory expedition under General George A. Custer entered the Black Hills to investigate rumors of gold. "Custer's florid descriptions of the mineral and timber resources of the Black Hills, and the land's suitability for grazing and cultivation... received wide circulation, and had the effect of creating an intense popular demand for the 'opening' of the Hills for settlement." [5] Initially the U.S. military tried to turn away trespassing miners and settlers. Eventually, however, President Grant, the Secretary of the Interior, and the Secretary of War "decided that the military should make no further resistance to the occupation of the Black Hills by miners." These orders were to be enforced "quietly" and the President's decision was to remain "confidential". [6]

As more and more settlers and gold miners invaded the Black Hills, the government concluded that the only practical course was to take the land from the Sioux, and appointed a commission to negotiate the purchase. [7] The negotiations failed, and so the US resorted to military force. They used as a pretext to declare the Sioux Indians "hostile" their failure to obey an order to return from an off-reservation hunting expedition in the dead of winter when travel was impossible. [8] The consequent military expedition to remove the Sioux from the Black Hills included an attack on their village on the Little Bighorn River led by Custer. The attack culminated in the victory of Chiefs Sitting Bull and Crazy Horse over the 7th Cavalry Regiment now known as Battle of the Little Bighorn. [9] [10]

That victory was short-lived. Those Indians who survived subsequent battles to surrender to the Army were interned on a reservation and deprived of their weapons and horses, "leaving them completely dependent for survival on rations provided them by the Government." [7] In August 1876, Congress enacted a bill cutting off appropriations "made for the subsistence" of the Sioux unless they ceded the Black Hills to the United States. A commission headed by George Manypenny presented the Sioux with a new treaty and they signed, under threat of starvation. [11] Only a few leaders signed, not the 3/4 majority of all Indian males on the reservation as required under the Fort Laramie Treaty. [12]

S. 590 (1876)

After the "Army's withdrawal from its role as enforcer of the Fort Laramie Treaty" the previous year [13] and its subsequent return to prepare for a military campaign against the Sioux, a bill was introduced in the U.S. Senate to authorize "a peaceful settlement" with the Sioux Nation for the Black Hills. [14] A proposed "five-member commission" would have asked the Sioux Nation to relinquish the "entire reservation" given to them under the Fort Laramie Treaty. From most "congressional and pioneer views" this was the "easy and practical method" of securing the Blacks Hills. [15]

S. 590 was approved by the Senate with a vote of thirty to eight, with language that implied that the commission could acquire the entire reservation and relocate the Sioux. [16] In the House Committee on Indian Affairs, it was amended to specify that "nothing in this bill could be construed or twisted to allow for the removal of the Sioux Nation to Indian Territory. [17] " Peace efforts or "attempts to purchase the Blacks hills" could still proceed. Missourians praised the action since it would have kept the Sioux far from their borders. [18]

However, after the Battle of the Little Big Horn public opinion turned against the Sioux and Congress refused to address the bill. When asked why, Congressman Omar Dwight opined that Congress felt the need to "find out whether the Sioux have captured all our army before we go treating with them." [19]

S. 590 went on to die in committee and Congress approved the Indian Appropriations Bill of 1876 instead. It "illegally denied the Sioux all further appropriation and treaty-guaranteed annuities" until they gave up the Black Hills. [20]

20th century litigation of the Sioux claim for the Black Hills

An image of the Black Hills taken from space Black hills from space.jpg
An image of the Black Hills taken from space

The Sioux never accepted the legitimacy of their forced deprivation of their Black Hills reservation. [21] In 1920, lobbyists for the Sioux persuaded Congress to authorize a lawsuit against the United States in US Claims Court. The Sioux filed a petition in 1923, but the Claims Court dismissed the case in 1942, holding that the Court could not second guess whether their compensation under the 1877 Agreement reached by the Manypenny Commission – which served as the basis for the 1877 Act of Congress – was adequate. [22] The Sioux (and many other tribes) continued lobbying Congress for a forum for their claims, and in 1946 Congress created an independent federal agency, the Indian Claims Commission, to "hear and determine all tribal grievances" including the Sioux claim. [23]

The Sioux lost their first hearing before the Indian Claims Commission "due to the failings of their former counsel", but on appeal to the US Claims Court, the Court directed the Commission to take new evidence, which it did in 1958. Then ensued what the US Supreme Court called "a lengthy period of procedural sparring" from 1958 until 1972 – when the Commission ruled in favor of the Sioux, awarding damages for the deprivation of the land, but not interest. [23] On appeal the Government did not contest the Commission's holding that it had "acquired the Black Hills through a course of unfair and dishonorable dealing for which the Sioux were entitled to damages." [24] In effect, the Government was disputing only whether the Sioux could collect 100 years' worth of interest. The Claims Court ruled that its previous 1942 dismissal of the Sioux’s Fifth Amendment Taking case was res judicata (a case already decided), "whether rightly or wrongly", thus denying the opportunity to seek 100 years' worth of interest. [25]

The case returned to the Indian Claims Commission to determine minor leftover issues about the value of rights-of-way and government offsets. In the meantime, in 1978 the Sioux lobbyists persuaded Congress to pass yet another law conferring authority on the Claims Court to hear the Sioux case, this time without regard to res judicata. That meant the Sioux could re-litigate the claim as a Fifth Amendment Taking, to collect 100 years' worth of interest. [23] Finally, under its new authorizing statute, the Claims Court held the Sioux had suffered a Taking cognizable under the Fifth Amendment, and were entitled to the value of the land as of the 1877 taking which was $17.1 million, the value of gold prospectors illegally took out of the land computed at $450,000, and 100 years' worth of interest at 5% per year which would be an additional $88 million. [26]

This Government appealed this decision, and the US Supreme Court granted its petition for certiorari. [27]

Supreme Court decision

Justice Blackmun delivered the Court's opinion in which six other justices joined. Justice White concurred in part, and Justice Rehnquist dissented. [28]

The issue was whether the Sioux had already received just compensation for their land, and the Court affirmed the Claims Court's decision that they never had. [29] The Court recognized a tension between Congress's duty to serve as a benevolent trustee for Indians, and the power to take their land. [30] "Congress can own two hats, but it cannot wear them both at the same time," said the opinion. [31] While reaffirming earlier decisions that Congress has "paramount authority over the property of the Indians," the Court concluded that Congress acts properly only if it "makes a good faith effort to give the Indians the full value of the land," which here it had failed to do. [32] In conclusion the Supreme Court ordered "just compensation to the Sioux Nation, and that obligation, including an award of interest, must now, at last, be paid." [33]

Dissent

Associate Justice William Rehnquist was the lone dissenter in this case. Rehnquist felt Congress overstepped the bounds of separation of powers by intruding upon the finality of a judicial decision when it "reviewed a prior decision of an Art. III court, [34] eviscerated the finality of that judgment, and ordered a new trial in a pending case." [35] Rehnquist also disagreed that the initial Court of Claims decision in 1942 was wrong. He endorsed the view that the Sioux already had been adequately compensated for their land. [36] Rehnquist's dissent suggests that it is "quite unfair to judge by the light of 'revisionist' historians or the mores of another era actions that were taken under pressure of time more than a century ago." [37]

Response to the decision

The Sioux have declined to accept the money, [38] because acceptance would legally terminate Sioux demands for return of the Black Hills. The money remains in a Bureau of Indian Affairs account accruing compound interest. As of 2011, the Sioux's award plus interest was "about $1 billion" or "1.3 billion" (equivalent to $1.35 to $1.76 billion in 2023). [39] [40]

In lieu of accepting the payment outlined by the Court, Sioux leaders created the Black Hills Steering Committee, a political group consisting of members from each Sioux tribe that coalesced around the shared goal of pressuring Congress to enact legislation that would reestablish Sioux sovereignty over the Black Hills territory. [41] Under the leadership of Gerald Clifford, the designated coordinator of legislative efforts, Sioux representatives spent two years negotiating the exact terms of their demands. The final legislative draft written by the Steering Committee called for the creation of a new reservation within the same territory acquired by the United States in 1877 that once constituted the Great Sioux Reservation, and totaled an approximate 7.3 million acres (30000 km2). [41] However, the Sioux would only receive direct title over 1.2 million acres (5000 km2) of federal land, as the State of South Dakota and private residents were permitted to retain ownership over their land. The legislation would also re-establish water and mineral rights to the Sioux in the reapportioned territory and restore tribal jurisdiction. It also included provisions that ensured the exemption of the territory under Sioux control from all federal, local, and state taxes. [42]

The Steering Committee succeeded in bringing this legislation to Congress when Senator Bill Bradley of New Jersey signed on as a sponsor and introduced it on July 17, 1985. [43] The new Sioux Nation Black Hills Act, or "Bradley Bill" as it was more commonly known, was staunchly opposed by the South Dakota delegation. The bill ultimately died in Congress without ever being brought up for a vote.

Bradley tried to reintroduce the legislation in 1987; however, internal political divisions amongst the representatives on the Black Hills Steering Committee diffused the momentum behind it. Steering Committee member Red Cloud proposed that the new legislative effort be led by Phil Stevens, a businessman from California who claimed Sioux ancestry, instead of Clifford. [44] Stevens claimed that the Bradley Bill was not sufficient and demanded, in addition to the restoration of 1.3 million acres (5250 km2) of territory, a sum of $3.1 billion in compensation and the guarantee of future rents on an additional 73 million acres (295 km2) that were included in the original Treaty of 1868 at a value of one dollar per acre to be paid each year. [45] Stevens' proposal earned him widespread support among many Sioux representatives. However, others in the Clifford camp were wary and criticized him for focusing too much on money rather than the return of Sioux land. Senator Bradley decided to hold back on the new bill until a resolution was reached for this internal dispute. [41] Ultimately, Stevens proved unable to secure any congressional support behind his alternative proposal, and the momentum behind the initial push behind the Bradley Bill was lost.[ citation needed ]

See also

Further reading

Related Research Articles

<span class="mw-page-title-main">Lakota people</span> Indigenous people of the Great Plains

The Lakota are a Native American people. Also known as the Teton Sioux, they are one of the three prominent subcultures of the Sioux people, with the Eastern Dakota (Santee) and Western Dakota (Wičhíyena). Their current lands are in North and South Dakota. They speak Lakȟótiyapi—the Lakota language, the westernmost of three closely related languages that belong to the Siouan language family.

<span class="mw-page-title-main">Sioux</span> Native American and First Nations ethnic groups

The Sioux or Oceti Sakowin are groups of Native American tribes and First Nations people from the Great Plains of North America. The Sioux have two major linguistic divisions: the Dakota and Lakota peoples. Collectively, they are the Očhéthi Šakówiŋ, or "Seven Council Fires". The term "Sioux", an exonym from a French transcription of the Ojibwe term Nadowessi, can refer to any ethnic group within the Great Sioux Nation or to any of the nation's many language dialects.

<span class="mw-page-title-main">Crow Agency, Montana</span> Census designated place in Montana, United States

Crow Agency is a census-designated place (CDP) in Big Horn County, Montana, United States and is near the actual location for the Little Bighorn National Monument and re-enactment produced by the Real Bird family known as Battle of the Little Bighorn Reenactment. The population was 1,616 at the 2010 census. It is the governmental headquarters of the Crow Nation Native Americans. It is also the location of the "agency offices" where the federal Superintendent of the Crow Indian Reservation and his staff interacts with the Crow Tribe, pursuant to federal treaties and statutes.

<span class="mw-page-title-main">The Dakotas</span> Region in the United States

The Dakotas, also known as simply Dakota, is a collective term for the U.S. states of North Dakota and South Dakota. It has been used historically to describe the Dakota Territory, and is still used for the collective heritage, culture, geography, fauna, sociology, economy, and cuisine of the two states.

<span class="mw-page-title-main">Red Cloud's War</span> Part of the Sioux Wars

Red Cloud's War was an armed conflict between an alliance of the Lakota, Northern Cheyenne, and Northern Arapaho peoples against the United States and the Crow Nation that took place in the Wyoming and Montana territories from 1866 to 1868. The war was fought over control of the western Powder River Country in present day north-central Wyoming and Montana.

<span class="mw-page-title-main">Treaty of Fort Laramie (1868)</span> US-Sioux treaty ending Red Clouds War

The Treaty of Fort Laramie is an agreement between the United States and the Oglala, Miniconjou, and Brulé bands of Lakota people, Yanktonai Dakota, and Arapaho Nation, following the failure of the first Fort Laramie treaty, signed in 1851.

<span class="mw-page-title-main">Indian reservation</span> Land managed by Native American nations under the US Bureau of Indian Affairs

An American Indian reservation is an area of land held and governed by a U.S. federal government-recognized Native American tribal nation, whose government is autonomous, subject to regulations passed by the United States Congress and administered by the United States Bureau of Indian Affairs, and not to the U.S. state government in which it is located. Some of the country's 574 federally recognized tribes govern more than one of the 326 Indian reservations in the United States, while some share reservations, and others have no reservation at all. Historical piecemeal land allocations under the Dawes Act facilitated sales to non–Native Americans, resulting in some reservations becoming severely fragmented, with pieces of tribal and privately held land being treated as separate enclaves. This intersection of private and public real estate creates significant administrative, political, and legal difficulties.

<span class="mw-page-title-main">John Fire Lame Deer</span> Lakota holy man (1903–1976)

John Fire Lame Deer was a Lakota holy man, member of the Heyoka society, grandson of the Miniconjou head man Lame Deer, and father of Archie Fire Lame Deer.

<span class="mw-page-title-main">Treaty of Fort Laramie (1851)</span> Treaty on territorial claims of Native Americans

The Fort Laramie Treaty of 1851 was signed on September 17, 1851 between United States treaty commissioners and representatives of the Cheyenne, Sioux, Arapaho, Crow, Assiniboine, Mandan, Hidatsa, and Arikara Nations. Also known as Horse Creek Treaty, the treaty set forth traditional territorial claims of the tribes.

<span class="mw-page-title-main">Great Sioux Reservation</span> Former Indian reservation in the United States

The Great Sioux Reservation was an Indian reservation created by the United States through treaty with the Sioux, principally the Lakota, who dominated the territory before its establishment. In the Fort Laramie Treaty of 1868, the reservation included lands west of the Missouri River in South Dakota and Nebraska, including all of present-day western South Dakota. The treaty also provided rights to roam and hunt in contiguous areas of North Dakota, Montana, Wyoming, and northeast Colorado.

<span class="mw-page-title-main">Republic of Lakotah proposal</span> Proposal of legal withdrawal from the USA

The Republic of Lakotah or Lakotah is a proposed independent republic in North America for the Lakota people. The idea of an independent nation of the Lakota was advanced in 2007 by activist Russell Means and the Lakota Freedom Movement. The suggested territory would be an enclave within the borders of the United States, covering thousands of square miles in North Dakota, South Dakota, Nebraska, Wyoming, and Montana. The proposed national borders are those laid out in the 1851 Treaty of Fort Laramie between the United States government and the Lakota tribes. These lands are now occupied by Indian reservations and non-Native settlements.

<span class="mw-page-title-main">Great Sioux War of 1876</span> Battles and negotiations between the US and the Lakota Sioux and Northern Cheyenne

The Great Sioux War of 1876, also known as the Black Hills War, was a series of battles and negotiations that occurred in 1876 and 1877 in an alliance of Lakota Sioux and Northern Cheyenne against the United States. The cause of the war was the desire of the US government to obtain ownership of the Black Hills. Gold had been discovered in the Black Hills, settlers began to encroach onto Native American lands, and the Sioux and the Cheyenne refused to cede ownership. Traditionally, American military and historians place the Lakota at the center of the story, especially because of their numbers, but some Native Americans believe the Cheyenne were the primary target of the American campaign.

<span class="mw-page-title-main">Indian Peace Commission</span> 1867 US government body

The Indian Peace Commission was a group formed by an act of Congress on July 20, 1867 "to establish peace with certain hostile Indian tribes." It was composed of four civilians and three, later four, military leaders. Throughout 1867 and 1868, they negotiated with a number of tribes, including the Comanche, Kiowa, Arapaho, Kiowa-Apache, Cheyenne, Lakota, Navajo, Snake, Sioux, and Bannock. The treaties that resulted were designed to move the tribes to reservations, to "civilize" and assimilate these native peoples, and transition their societies from a nomadic to an agricultural existence.

<span class="mw-page-title-main">Seizure of the Black Hills</span> Land dispute between Native Americans and the US government

The United States government illegally seized the Black Hills – a mountain range in the US states of South Dakota and Wyoming – from the Sioux Nation in 1876. The land was pledged to the Sioux Nation in the Treaty of Fort Laramie, but a few years later the United States illegally seized the land and nullified the treaty with the Indian Appropriations Bill of 1876, without the tribe's consent. That bill "denied the Sioux all further appropriation and treaty-guaranteed annuities" until they gave up the Black Hills. A Supreme Court case was ruled in favor of the Sioux in 1980. As of 2011, the court's award was worth over $1 billion, but the Sioux have outstanding issues with the ruling and have not collected the funds.

Ex parte Crow Dog, 109 U.S. 556 (1883), is a landmark decision of the Supreme Court of the United States that followed the death of one member of a Native American tribe at the hands of another on reservation land. Crow Dog was a member of the Brulé band of the Lakota Sioux. On August 5, 1881 he shot and killed Spotted Tail, a Lakota chief; there are different accounts of the background to the killing. The tribal council dealt with the incident according to Sioux tradition, and Crow Dog paid restitution to the dead man's family. However, the U.S. authorities then prosecuted Crow Dog for murder in a federal court. He was found guilty and sentenced to hang.

The following outline is provided as an overview of and topical guide to United States federal Indian law and policy:

Arthur Lazarus Jr. was an American lawyer primarily known for his work with American Indian tribes and Alaska Native corporations. His clients included the Blackfeet, Tuscarora, Seneca, and Navajo. His best-known case was the Black Hills Land Claim on behalf of the Sioux.

This timeline of South Dakota is a list of events in the history of South Dakota by year.

<span class="mw-page-title-main">Early Indian treaty territories in Montana</span>

A number of different Native Americans living in present-day Montana entered into treaties with the United States during the 19th Century. Most of the treaties included an article that established the territory of the tribe entering into it. More and more of this Indian land turned into public or U.S. territory with the signing of new treaties..

<span class="mw-page-title-main">Early Indian treaty territories in North Dakota</span>

Native Americans from various tribes lived in North Dakota before the arrival of settlers. With time, a number of treaties and agreements were signed between the Indians and the newcomers. Many of the treaties defined the domain of a specific group of Indians. The three maps below show the treaty territories of different Indians living in North Dakota and how the territories changed and diminished over time in the 19th century.

References

  1. ↑ United States v. Sioux Nation of Indians, 448 U.S. 371, 376 (1980) ("US v Sioux Nation").
  2. ↑ US v Sioux Nation 448 US 371 at 376–77.
  3. ↑ "United States v. Sioux Nation of Indians 448 U.S. 371 (1980)". Justia Law. Retrieved February 24, 2016.
  4. ↑ US v Sioux Nation, 448 U.S. 371, 374.
  5. ↑ "US v Sioux Nation" 448 US 371 at 377.
  6. ↑ "US v Sioux Nation" 448 US 371 at 378.
  7. 1 2 "US v Sioux Nation" 448 US 371 at 379.
  8. ↑ "US v Sioux Nation" 448 US 371 at 379–380.
  9. ↑ '"US v Sioux Nation" 448 US 371 at 379.
  10. ↑ Philbrick, Nathaniel (2010). The Last Stand: Custer, Sitting Bull, and the Battle of the Little Bighorn . Viking. ISBN   978-0-670-02172-7.
  11. ↑ "US v Sioux Nation" 448 US 371 at 381.
  12. ↑ "US v Sioux Nation" 448 US 371 at 382.
  13. ↑ "448 U.S. 371 (1980) UNITED STATES v. SIOUX NATION OF INDIANS ET AL".
  14. ↑ "The Sioux Nation and Indian Territory: The Attempted Removal of 1876" (PDF).
  15. ↑ "The Sioux Nation and Indian Territory: The Attempted Removal of 1876" (PDF).
  16. ↑ "The Sioux Nation and Indian Territory: The Attempted Removal of 1876" (PDF).
  17. ↑ "The Sioux Nation and Indian Territory: The Attempted Removal of 1876" (PDF).
  18. ↑ U.S., Congress, Woüse, Journal. 44th Cong., 1st sess., 1875-1876, pp. 1050, 1084; U.S., Congress, House, Committee on Indian Affairs, Index of Reports of Committees of the House of Representatives, H. Rept. 674, 44th Cong, 1st sess 1875-1876 (SeriaH712), p. \, St. Louis Republican. 1 June 1876.
  19. ↑ House Journal, 44 Cong., 1 sess., 1875-1876, p. 1257; House, Congressional Record, 44 Cong,, 1 sess., 1875-1876, 4, pt. 5:4520
  20. ↑ Wilkins, David E. (2010). American Indian Sovereignty and the U.S. Supreme Court: The Masking of Justice. University of Texas Press. ISBN   978-0-292-77400-1.[ page needed ]
  21. ↑ '"US v. Sioux Nation, 448 US 371 at 384.
  22. ↑ US v. Sioux Nation 448 US 371 at 384.
  23. 1 2 3 US v. Sioux Nation, 448 US 371 at 385.
  24. ↑ US v. Sioux Nation, 448 US 371 at 387.
  25. ↑ US v. Sioux Nation, 448 US 371 at 388.
  26. ↑ US v. Sioux Nation, 448 US 371 at 390, footnote 16.
  27. ↑ Fredericks, Carla F. (June 14, 2017). "Standing Rock, the Sioux Treaties, and the Limits of the Supremacy Clause". University of Colorado Law Review. Retrieved July 6, 2020.
  28. ↑ U.S. v. Sioux Nation, 448 U.S. at 373.
  29. ↑ U.S. v. Sioux Nation, 448 U.S. at 420–21.
  30. ↑ U.S. v. Sioux Nation, 448 U.S. at 408–09.
  31. ↑ U.S. v. Sioux Nation, 448 U.S. at 408.
  32. ↑ U.S. v. Sioux Nation, 448 U.S. at 409.
  33. ↑ U.S. v. Sioux Nation, 448 U.S. at 423.
  34. ↑ A federal court established under Article III of the U.S. Constitution. The Claims Court was not an Article III court at the time it decided the Sioux case in 1942, but became one in 1953 before the 1970s decisions.
  35. ↑ '"US v Sioux Nation" 448 US 371 at 434.
  36. ↑ '"US v Sioux Nation" 448 US 371 at 434–35.
  37. ↑ "US v Sioux Nation" 448 US 371 at 435.
  38. ↑ Frederic Frommer (August 19, 2001). "Black Hills Are Beyond Price to Sioux". Los Angeles Times. Archived from the original (Suggested Reading Black Elk Speaks and Articles Below) on November 11, 2014. Retrieved December 28, 2013.
  39. ↑ Streshinsky, Maria (February 9, 2011). "Saying No to $1 Billion". The Atlantic. Retrieved December 28, 2013.
  40. ↑ LeGro, Tom (August 24, 2011). "Why the Sioux Are Refusing $1.3 Billion". PBS NewsHour. Retrieved July 6, 2020.
  41. 1 2 3 Lazarus, Edward (1999). Black Hills White Justice: The Sioux Nation Versus the United States, 1775 to the Present. U of Nebraska Press. ISBN   978-0-8032-7987-2.[ page needed ]
  42. ↑ "Section-by-Section Analysis of the Bradley Bill". Wíčazo Ša Review. 4 (1): 13–17. Spring 1988. doi:10.2307/1409075. JSTOR   1409075.
  43. ↑ Giago, Tim (May 25, 2011). "The Black Hills: A Case of Dishonest Dealings". Huffington Post. Retrieved April 14, 2018.
  44. ↑ Gonzalez, Mario, and Cook-Lynn, Elizabeth. The Politics of Hallowed Ground: Wounded Knee and the Struggle for Indian Sovereignty / Mario Gonzalez and Elizabeth Cook-Lynn. Urbana: U of Illinois, 1999. Print.
  45. ↑ Gregg, PR, II (September 20, 1988). "Town forum suggests sharp division among Sioux tribal members". Indian Country Today. Oneida, N.Y. p. 1. ProQuest   371473745.{{cite news}}: CS1 maint: multiple names: authors list (link)

Further reading

This page is based on this Wikipedia article
Text is available under the CC BY-SA 4.0 license; additional terms may apply.
Images, videos and audio are available under their respective licenses.