The Indian Reorganization Act of 1934: Native American Rejection and Resistance

Annabella Pizzi

   “Hailed by white and Indian supporters” alike, The Indian Reorganization Act of 1934 was anticipated to be the most forward-looking and influential piece of federal Indian policy ever passed by Congress [1]. Enthusiastically referred to as the “Indian Bill of Rights,” the act aimed to free Native Americans from destructive pieces of former legislation, and grant them the resources necessary for tribal sovereignty and self determination [2]. In practice, however, the Indian Reorganization Act fell short in achieving what it sought to accomplish. Anticipated to be a supportive and progressive turning point in Native American legal history, significant opposition and discontent arose from the ratification of the Indian Reorganization Act in 1934. This paper will analyze the creation and subsequent reception of the Indian Reorganization Act, characterized by Native opposition as expressed through Indigenous peoples and Native Studies scholars to better understand the still complicated relationship between Indigenous communities and the federal government today. 

   The history of Native Americans is one of strife, characterized by great loss of culture and land. For the purpose of this paper, this history begins with The Indian Removal Act of 1830. The Indian Removal Act “authorized the President to negotiate removal treaties with Indian tribes living east of the Mississippi River, primarily in the states of Georgia, Tennessee, Alabama, Mississippi, North Carolina, and others” [3]. The ultimate goal of the act was to relocate all Native peoples in these areas to the unsettled, western territories. Perhaps the most infamous result of the Indian Removal Act of 1830 is President Andrew Jackson’s Trail of Tears where the Cherokee people of the southeastern United States were forcibly removed from their ancestral homelands to western territory between 1838 and 1839. Due to starvation, military brutality, and physical exhaustion, over four thousand Cherokee people died, equating to about one fifth of the entire tribal population [4].

   In 1851 and 1871 Congress passed The Indian Appropriations Acts to further restrict Native peoples. The Appropriations Act of 1851 created Indian reservations and continued the forceful removal of Native peoples that began in 1830. Under this Appropriations Act, Native peoples were removed from their homelands in the eastern United States to “small tracts of land” in the western territories, thus allowing “the government to free up indigenous land so that it could more easily be redistributed” to white settlers moving westward while simultaneously making indigenous people easier to subdue [5]. The 1871 Appropriations Act ended tribal sovereignty in the United States, no longer recognizing any Native tribe as “an independent nation” [6]. Furthermore, the government asserted that all Native Americans were henceforth considered wards of the American government, not foreign citizens, as they had been before 1871. 

   Sixteen years after The Appropriation Act of 1871 was ratified, the federal government passed the 1887 General Allotment Act “to promote the assimilation of Indians into white society” through the distribution of land allotments [7]. This act took the reservation lands that had been created by the 1851 Appropriations Act and divided them all into “160 acre allotments, assign[ed] one to each family, and open[ed] the remaining lands to white settlers” [8]. Native peoples under the age of eighteen received 40 acres “and each single person or orphan 80 acres” [9]. These lands came from the reservations of the “‘Five Civilized tribes—Cherokee, Chickasaw, Choctaw, Creek (Muscogee), and Seminole,” mainly located in Oklahoma territory [10]. 

   Once in possession of an allotment, Native Americans became United States citizens, and “became subject to the laws of the territory or states in which they resided” [11]. The allotted land was placed in trust by the government for a period of twenty five years to supposedly protect Native peoples while they adopted white farming techniques [12]. Assimilationists believed that through land allotments, Indigenous people would “acquire the habits of thrift, industry, and individualism” [13]. By placing Native Americans on allotments, politicians believed that they would be able to better destroy “Native collective identity due to the inextricable connection between Native tribal lands and forms of Native belonging down to the most intimate level, the Native family” [14]. 

   The Dawes Act was destructive for its success in removing many Native Americans from their ancestral homelands and fragmenting many tribes, but also for its failure to economically assimilate Native peoples into the American economy, due to widespread lack of resources and unfarmable land placements. The vast majority of Native Americans forced onto allotments did not have the savings needed to “use their allotments productively” [15]. They “lacked the capital and credit that they needed to purchase seeds, equipment, and stock” [16]. Even if these Native peoples had the funds necessary to grow their crops, they were additionally disadvantaged when it came to the quality of land they had been allotted. Many of the allotments were on unfarmable land, due to arid conditions, lack of water, frigid temperatures, generally poor soil, or a mix of all three conditions [17]. Many Native Studies scholars, including Janet A. McDonnell assert that it was “unreasonable for Congress and the Indian Office to expect anyone to farm this land successfully,” yet they did [18]. Though there are always exceptions, in many cases, the result of the Dawes Act was widespread resentment towards the federal government, and extreme rates of poverty amongst Native peoples—both of which were exacerbated over time. 

   After the initial ratification of the act, the federal government made amendments in 1891, 1903, and 1906. These amendments gave the wives of allotment holders land “equal in size to those of their husbands,” the right to lease their lands, the ability to “sell heirship allotments,” sell their allotments entirely, and gave the federal government the power to “lengthen or shorten the 25-year trust period for allotted land” [19]. Instead of helping, these amendments resulted in increased bureaucratic power of the Bureau of Indian Affairs, and altered the function of the Dawes Act for the worse. Initially intended to teach Native Amercians to “how to manage private property,” the purpose of the act began to shift in 1891 to “an administrative problem in which the federal government was assumed to be the supervisor of how Indian property was used” [20]. Before the implementation of the General Allotment Act of 1887, Native American tribes owned “138,000,000 acres of land,” but by 1934, due to governmentally established reservations and allotments, Native American lands were reduced to “forty-seven million acres.” Of that “forty-seven million acres” [21], over twenty million acres was desert land, making it infertile and virtually unlivable [22]. With this “ninety-one million acre reduction,” the federal government thus expanded its authority over Native peoples, and exerted even more control than before, leading to greater hatred towards them [23]. 

   The compulsory nature of the Dawes Act only worsened the already controversial nature of the Dawes Act. The Bureau of Indian Affairs purposefully ignored cultural traditions in hopes of erasing them from Native life. Many Native American societies relied on hunting and sustenance based farming to survive, not “materialistic commercial farming,” the method to which the government expected Natives to spontaneously switch [24]. The American government expected this shift immediately, but failed to provide them with the agricultural education or funds needed to make such drastic changes. 

A great number of people, Native and non-Native, called for change. The most notable proponent of Indigenous rights was John Collier. Collier, an alumnus of Columbia University, and the Collège de France, had committed himself to aiding underserved committees of American society. In 1923 he founded the American Indian Defense Association (AIDA) with the purpose of educating the largely white public on Native lives, and “to promote government policies that, in the words of the IDA [AIDA], ‘would permit the Indian to remain spiritually and physically on this earth’” [25]. John Collier was vocal in his criticism of the federal Indian policy, and Bureau of Indian Affairs, arguing that their policies had had detrimental effects on the livelihoods of Native Americans. The American Indian Defense Association was therefore created with the intention “to protect Indian rights to their land as well as their rights to practice their own religions” [26].

  The disproportionate rates of poverty experienced by Native Americans in subsequent decades is attributed to the failure of the Dawes Act to create the economic opportunities it had hoped to achieve. The Meriam Report of 1928, also known as The Problem of Indian Administration, was written by Lewis Meriam, a “statistician” from the Institute for Government Research, who had been commissioned by the Rockefeller Foundation to conduct a report on the conditions of the American Indian [27]. The “survey of conditions on Indian reservations in twenty six states” found the living environments of Native peoples deplorable [28]. The report charged the government with “impropriety by the Bureau of Indian Affairs in Indian land matters; reported conditions of poverty and disease among Indians; and the apparent lack of success in acculturating Indian people into the rest of American society” [29]. Though Hubert Work, the Secretary of the Interior, sponsored the Meriam Report under the provision of President Calvin Coolidge, the federal government subsequently made little effort to improve the impoverished conditions of Indigenous peoples. 

   Only a new administration would see the legislative changes of direct consequence to Native peoples. In 1932, Franklin D. Roosevelt was elected president and told the American people that he would dedicate his time in office to alleviate the economic strain of the Great Depression. “The first days of Roosevelt’s administration saw the passage of banking reform laws, emergency relief programs, work relief programs, and agricultural programs” [30].  A term taken from one of his own speeches, Roosevelt’s reform initiative was called the “New Deal” [31].

   The vast majority of New Deal legislation benefited white Americans and not Natives. With his “reforms to relieve poverty and unemployment,” Native Americans, one of the most impoverished racial communities in the country, as demonstrated in the Meriam Report, Roosevelt could not ignore Indigenous peoples as other politicians had [32]. Roosevelt’s appointment of John Collier to the Commissioner of Indian Affairs elicited some change. Roosevelt believed that Collier would be the change that the Bureau of Indian Affairs needed to incite effective reform for Native Americans. Especially following the publication of the Meriam Report, Collier wished to pass legislation to help the horrifying conditions of Native peoples. The policies largely created by Collier under the Roosevelt Administration would later be known as the Indian New Deal, a parallel to white America’s New Deal. 

   The Indian New Deal was composed of a few pieces of legislation as well as cultural and preservation minded programs. However, the most influential and controversial Indian New Deal legislation passed was The Wheeler- Howard Act, or the Indian Reorganization Act of 1934. This act was originally sponsored and named after Senator Burton K. Wheeler of Montana and Representative Edgar Howard of Nebraska. The first draft of the document, called The Howard Wheeler Bill, was eleven pages long and was separated into four titles: Indian Self- Government, Special Education for Indians, Indian Lands, and Court of Indian Affairs [33]. This original proposal was regarded as “the most comprehensive and far-reaching legislative vision ever offered to Congress” [34]. The Howard-Wheeler Bill was said to have “responded to every possible area that could have been anticipated by the government or Indians,” giving special attention to issues presented in the Meriam Report [35]. With Collier as supervisor, the draft was written by a team of fifteen lawyers and other officials from the Department of the Interior over the course of several months following Collier’s appointment to commissioner [36].

   In an original act of outreach by the federal government, John Collier wanted to present the Howard-Wheeler Bill (the eleven page bill) to Native communities that it would impact before the legislation was ratified. Collier claimed that he also wanted to “dispel the anxieties of Indians” who had only heard rumors of the bill, and receive feedback from various tribes on the provisions of the act [37]. Though the latter claim about feedback is debatable, as the bill’s amendments were almost entirely impacted by congressional debate, and not Native concern, Collier’s forums were certainly unprecedented. Collier’s “congresses” to ten different western locations began in March of 1934, and were spread out over the course of the next year [38]. Together with fellow employees of the Bureau of Indian Affairs and the Department of the Interior, Collier held congresses in Rapid City, South Dakota, Chemawa, Oregon, Fort Defiance, Arizona, Riverside, California, Anadarko, Oklahoma, Muskogee, Oklahoma, Hayward, Oklahoma, Miami, Oklahoma, and Hayward, Wisconsin [39]. All of these congresses were held before the IRA was passed on June 18, 1934, with the last one in Hayward, Wisconsin on April 24, 1934 [40].

   Collier’s congresses lasted at least two days at each location, and all followed a similar structure. The congresses often started with introductions and thanks expressed by Collier. Collier then explained his view of Native American life, to acknowledge the poor conditions faced by Native peoples in the United States, and further asserts that it was the fault of the federal government for subjecting indigenous peoples “to the mercy of the Indian Bureau” [41]. Collier assured the congresses that the Howard- Wheeler Bill would be the solution to Native loss of land rights, and troubles that came with Indian wardship [42]. 

   In the first congress held in Rapid City, South Dakota, Collier argued that unlike its neighboring countries of Canada and Mexico, Natives peoples of the United States were seemingly always discontent with the federal government. Collier did take accountability on behalf of the federal government for the disservices committed, and declared that though the United States was an “intelligent” and “powerful” nation, it could not “go on disgracing itself in its handling of Indian matters” [43]. In many of the other congresses, Collier then explained the ratification process of a bill to a law, before providing all peoples with a copy of the bill to read. In many cases including the Plains Congress of Rapid City, South Dakota, the bill was distributed in English, but was promised to be translated to the Native languages of those present at the congress in the near future [44]. Collier then opened the floor to questions by Native people. Specific questions varied across the ten congresses, though many were about the new organization of land and access to specific resources, such as water and minerals [45]. 

While Collier was holding his congresses with Native tribes, the same draft of the bill he was presenting was also under review in several congressional committees, starting in January of 1934. The Howard- Wheeler Bill was subject to congressional scrutiny through the remainder of the winter and into the spring months. Many congressmen argued that the proposed bill would give Native Americans substantially more power and autonomy than they were capable of having and that the federal government was willing to cede. 

The bill was so contested that only an appeal of support made by Collier and the Secretary of the Interior to President Roosevelt halted committee debates. Following President Rooselvelt’s support of the act, the congressional committees began to make notable progress in their discussions. Unbeknownst to the tribes during Collier’s congresses, the congressional committees made serious edits to the bill, including the removal of sections “promoting the preservation and enhancement of Indian culture…[and] Indian court provisions”[46]. All sections giving tribes explicit rights to self government were restricted, and instead “made subject to the approval of the Secretary of the Interior”[47] Allotted lands could be voluntarily given to communal tribal ownership- a mandatory clause in Collier’s original bill. The bill was also made to restrict, if not explicitly ban tens of thousands of Native peoples who were members of tribes the government did not officially recognize, including many Indigenous people from Oklahoma and Alaska [48]. Committees made drastic cuts to the appropriations listed in the first draft, such as the restriction of appropriated funds for the support of tribal governments. Funds were reduced by half; tribal government funds were initially “not to exceed $500,000 in any one fiscal year,” but the final draft reduced those funds to no more than $250,000 annually [49]. Committees edited the bill’s definition of “Indian,” stating that Collier’s “one-fourth Indian blood” policy was too generous, amending the bill to only qualify those who were at least “one-half Indian blood” for any benefits of the Indian Reorganization Act.[50]. Finally, Congressman Howard successfully pushed for the act to be non-compulsory, because the General Allotment Act had not been, in an attempt to create the illusion of increased autonomy of tribes, thus mitigating potentially negative Native responses to the act [51]. Historian Lawrence C. Kelly wrote that the referendum added by Representative Howard was not meant to allow for more indigenous autonomy, but was added rather as a way of masking an assimilationist agenda, and further “integrating Indians into the white economic system” [52]. While Collier sent his feedback from the tribes to the House Committee on Indian Affairs on April 15, 1934, the vast majority of edits to the bill had already been made. 

The Indian Reorganization Act (IRA) was ratified into law on June 18, 1934, but the final document’s reduction from eleven to three pages, only somewhat preserved the sentiment of the original The Howard- Wheeler Bill [53]. The Wheeler- Howard Act, “was part of Collier’s attempt to encourage economic development, self-determination, cultural plurality, and the revival of tribalism,” all of which had been destroyed by the Dawes Act of 1887 [54]. The IRA was radically different from former legislation as it “was intended to provide a mechanism for the tribe as a governmental unit to interact with and adapt to a modern society, rather than to force the assimilation of individual Indians” [55]. Though the effects of the General Allotment Act could never be completely undone, Collier hoped that his dissenting approach to Indian affairs would give many Native peoples the resources needed to overcome the conditions of extreme poverty that the Dawes Act had created. 

The ratified act was composed of nineteen sections total, each addressing a different issue. Some sections dealt with the appropriation of funds, others established the specific rights of Native individuals and tribes under the supervision of the Secretary of the Interior. To indigenous peoples to whom the IRA applied, the most controversial sections of the act were the first, fifth, sixth, eighteenth, and nineteenth sections. The first section of the IRA provides a succinct summary of the act, and reads as follows: 

An Act to conserve and develop Indian lands and resources; to extend to Indians the right to form bussiness and other organizations; to establish a credit system for Indians; to grant certain rights of home rule to Indians; to provide for vocational education for Indians; and for other purposes. Be it enacted by the Senate and House of Representatives of the United States of America in Congress assembled, That hereafter no land of any Indian reservation, created or set apart by treaty or agreement with the Indians, Act of Congress, Executive order, purchase, or otherwise, shall be allotted in severalty to any Indian. [56] 

Section I of the IRA acts as a preamble to the rest of the document, with the final clause overturning the General Allotment Act of 1887. According to the last sentence of section one, the federal government was no longer allowed to allot land to Native Americans. [57] Collier believed that in order to attempt to fix the destruction of allotment policies, the federal government first had to abolish the act. Section I of the act was generally well received, but Collier failed to take into account that while destructive to Native culture, the Dawes Act had achieved some “success” in its efforts to assimilate certain Native peoples. Some Natives had been either somewhat or completely assimilated into Anglo- American society, and did not want the federal government to grant control over their now private property back into tribal ownership [58]. Native peoples in this position begin to fear for the future of their property and work they had put into the development of their lands. 

Section V of the IRA greatly expanded the powers of the Secretary of the Interior. This section gave the Secretary of the Interior the authority over “any interest in lands, water rights or surface rights to lands… for the purpose of proving lands for Indians” [59]. These lands or resources could be located on or off reservations, allotments, or any land in trust [60]. Section V was created with the intention to provide Native peoples access to the resources that the Dawes Act had stripped them of, but in practice hurt them even more. Now access to land, water, minerals, etc., that Native peoples relied on to live was further restricted by the federal government. Much less controversial than the first half of the section, the final clause of Section V mandated that “title to any lands or rights acquired pursuant to this Act” were going to be taken into trust by the federal government, and would not be taxed as a result [61]. 

The following section, Section VI, created and gave the Secretary of the Interior the power to create and regulate “Indian forestry units,” and “restrict the number of livestock grazed on Indian range units”[62]. The Secretary of the Interior now had the authority to mandate the creation of forestry units to be cared for by Native peoples on their reservation lands. Native tribes were especially opposed to the restrictions on livestock; though the act stated that this new limitation was to protect the land from deterioration, tribes had relied on livestock cultivation for their livelihoods for generations [63]. 

Section XVIII of the IRA gave tribes the choice to adopt or not to adopt the IRA, stating that the act would “not apply to any reservation wherein a majority of the adult Indians” voted against the act [64]. Native men over the age of twenty- one were eligible to vote in tribal elections. As stipulated in the act, tribal elections would take place “within one year after the passage and approval” of the IRA in Congress [65]. If a tribe’s eligible majority voted in favor of the act, if they failed to raise a majority against, or did not vote at all, the IRA applied to the tribe [66]. The IRA would not apply to any tribe in which the majority of eligible voters “vote[d] against its election” [67]. 

Section XIX, defined “Indian” and “tribe” under the act. According to the IRA, an “Indian” was a person “of Indian descent” who was at least “one- half or more Indian blood,” and was residing or directly related to an individual residing on a federally recognized reservation before June 1, 1934.68 Furthermore, the act defined a “tribe” as “any Indian tribe, organized band, pueblo, or the Indians residing on one reservation” [69]. Only individuals and groups of people that met these qualifications were to receive the benefits enumerated in the IRA.  

The IRA’s passage on June 18, 1934 yielded myriad reactions from a wide array of peoples. For starters, Collier was thrilled to see the act passed, hoping that his dream of a “Red Atlantis” would be realized by the unanimous approval of all 252 federally recognized tribes [70]. Some Native tribes had waited in great anticipation of the IRA, in hopes of improved living conditions and greater governmental benefits. Some Natives were wary of increased governmental control and suspicious of the federal governmental motives. Others were vehemently opposed to the IRA, and in expressions of agency, voted against the act in tribal elections, and formed national organizations to protest. 

Almost immediately after the IRA was passed by Congress, a Native activist group, the American Indian Federation (AIF), was formed in August of 1934 in Gallup, New Mexico. This organization “grew from the Oklahoma- based Indian National Confederacy” [71]. Though a “loose federation composed of diverse Native communities,” the AIF presented a strong oppositional front against the IRA from its founding until 1939 [72]. The federation was founded and headed by Joseph Bruner (“a wealthy, full-blood Creek”), Alice Lee Jemison (Cattaraugus Seneca), O.K Chandler (Cherokee), W.W. LeFlore (Choctaw), and Delos K. Lone Wolf (Kiowa) [73]. With the exception of Alice Lee Jemison, “Oklahmonas… dominated the federation and its leadership” [74]. Though Joseph Bruner was elected president of the federation, Alice Lee Jemison is consistently cited as the most influential figure in the AIF for her lobbying efforts in Congress and press connections. With the exception of W. W. LeFlore as secretary, the other founders did not have official titles, but brought their expertise in agriculture, education, law, and the internal workings of the Bureau of Indian Affairs to the federation. From the beginning and through the remainder of the 1930s, the AIF had a strong following, and as of 1936, was composed of over 40 different tribes [75]. 

The founders and followers of the AIF were of diverse Native backgrounds, thus the AIF was attractive to different tribes across the United States for different reasons. 

Navajos were attracted to the organization because of its opposition to the government's callous administration of the herd reduction program; North Carolina Cherokees because of the Interior Department's attempts to extend the Blue Ridge Parkway through the heart of their Qualla Boundary Reservation; Sioux because of longstanding factional rivalry and the subordination of traditionalists in the elected systems created under the IRA; the Iroquois largely because of historic longheld fears about the repudiation of the Treaty of Canandaigua of 1794; California Indians because of increasing bureau jurisdiction and supervision of their lives prior to the New Deal as well as the continued lack of federal recognition of eighteen unratified treaties;10 certain Oklahoma tribesmen because of their greater historic amalgamation into non-Indian life;" and Lumbees because of the federal government's failure to recognize them as a tribe or even as Indians.” [76] 

Not all federally recognized tribes above rejected the IRA in the tribal voting and referendum process, but the range in reasoning and support of the AIF is notable. 

From its inception, the AIF staunchly advocated for three main reforms in the Indian Bureau: the destruction of the Indian Bureau, the removal of John Collier from his position as Commissioner of Indian Affairs, and the repeal of the Indian Reorganization Act [77]. Bruner argued that the federal government had committed countless wrongs against Native Americans since its founding. Bruner stated that for land losses alone, the American government would collectively owe Native Americans nine billion dollars, and was in favor of Native “emancipation” through “a final cash settlement” for land and other grievances [78]. 

Through countless appeals to the Senate and House of Representatives, multiple letters to FDR and the Secretary of the Interior, AIF lobbyists’ persistence influenced one settlement presented by Representative Burdick and Senator Elmer Thomas of Oklahoma in April of 1939 [79]. The Settlement Bill, also referred to as the “Oklahoma Indian Racket” by Collier, moved to give a settlement of three thousand dollars to any “‘enrolled, recognized, or allotted indian Indians… or their heirs (being voluntary members of the AIF)’” who agreed to “accept the full responsibilities of American citizenship” and to legally agreed that this payment would be a complete settlement of all grievances with the government in regards to Native land [80]. Though this bill was never made into law, disagreements divided the AIF. Some members, like Jemison, argued that the Settlement Bill went against everything that the AIF was fighting for, and was a sorry piece of legislation meant to subdue Native Americans [81]. Other members, such as Bruner, W.W. LeFlore, and Chandler, were in favor of the bill, as it did grant some form of payment to Native peoples [82]. 

Ultimately, the bill never passed in Congress. But, it did have a lasting impact on the AIF. After five years of tirelessly fighting for the AIF and its founding principles, Jemison believed that the federation “had lost its direction” [83]. This sentiment, coupled with allegations of Bruner and other members’ involvement and support of American Nazi organizations and the KKK, led to Jemison's resignation from the organization in 1939. With its loss of credibility as an organization for its poor connections and Jemison’s leave in 1939, the AIF was never able to regain what little progress it made in Congress, and the influence it had in Native communities again. 

 As Section XIX dictated, a referendum would determine the act’s application to tribes. While the numbers were debated, the “only official figures” on the statistics of the IRA referendum “appeared in a 1940 hearing conducted before the House Indian Affairs Committee” [84]. The numbers recorded in the 1940 hearing showed that of the 252 eligible tribes, 174 either voted in favor or failed to vote on the act, thus making it applicable to them, and 78 tribes explicitly voted against the act [85]. The seventy- eight tribes that voted against the IRA were the Navajo, Nez Percé, Coeur d'Ale, Montana Crow, Assiniboine and Sioux of Fort Peck, Jemez Pueblo, Turtle Mountain Chippewa, Devil's Lake Sioux, Klamath, Umatilla, Silets, Crow Creek, Sisseton Sioux, Spokane, Colville Yakima, Lummi, and Shoshone-Arapaho. The Puyallup tribe also voted against the act, but was subsequently admitted to its benefits because less majority of the tribe had participated in the election. In addition to these major tribes, forty-five bands of California Indians, six bands in Nevada, two in Washington, and all six tribes in New York voted against the act [86]. 

From these tribal based statistics historians have calculated that 97,243 Native Americans were eligible to vote for the IRA [87]. Of that total 38,054 favored the act, 23,894 were against, and 35,295 did not vote at all [88]. The failure to vote in IRA elections remains unclear. It is possible that not voting was a conscious decision as an expressional of autonomy and protest of the federal government. It is possible that some tribes were unaware of the implications of the act, and did not vote because they did not understand exactly what they would be voting for, though these explanations are mere speculation. 

The reasoning for so many opposing tribes also remains largely unclear. Historian Lawrence C. Kelly notes that the government gave “little attention… to the tribes which voted against the act,” a statement supported by historian Ronald N. Satz, who elaborates writing that Collier was “a masterful propagandist who was confident in his own powers of persuasion,” and was unable to accept that the act was not unanimously adopted across Native America, despite the IRA’s referendum [89]. Collier expressed discontent especially with the Navajo tribe, because he believed they would be one of the strongest supporters of the IRA. Collier asserted that “duress and bribery were not possible and were not attempted,” he had strongly urged the Navajo Tribal Council to adopt the IRA, believing it would help them fix their “immature political institution,” and would save them from their own incapability and frailty [90]. In referring to the IRA as the new “Indian Bill of Rights,” Collier believed that the IRA presented a perfect solution to all economic, social, and political problems faced by all Native American peoples in the United States [91]. Collier was completely mystified when all 252 federally recognized tribes did not adopt the act, and was further bewildered by Native opposition to the IRA [92]. 

The limited information on opposing tribes cites intertribal governmental objections and economic reasons for not enrolling under the IRA. Two of the strongest opponents of the IRA were Eastern Iroquois tribes of New York state and the Navajo. The IRA referendum statistics recorded that “all six tribes in New York voted against the act” [93]. One New York Times article published on June 15, 1935 gave a more specific account, recording that four of the six New York tribes had voted against the act at the time of the article’s publication: the Cattaraugus Seneca, Allegany, Tuscarora, and Tonawanda tribes [94]. The Onondagas were to vote on June 16, 1935, and given the congressional account of six total rejections, must have also voted against the IRA [95]. The final of the six tribes, the St. Regis Mohawks, did not legally reject the IRA. In their tribal vote, the St. Regis Mohawks strongly objected to the bill, but “the majority of their enrolled voters failed to register a preference” on their ballots, and the act was thus applied to the tribe by default [96]. The New York tribes were wary of the federal government, “were afraid that such action on their part might ultimately lead to an infringement upon their sovereignty” [97]. Despite the successes Congress sought to sell them with the IRA, New York Native Americans did not want anymore “white interference,” and wished the government would uphold the historical treaties they had already made with the tribes [98]. 

According to Native Historian Laurence M. Hauptman of the State, many of the New York tribes that voted against the IRA belonged to the Eastern Iroquois’ Six Nations confederation. Hauptman writes that the Iroquois people have a “unique concept of their own sovereignty,” and the Iroquois’s differing governmental structure from the United States was the reason for conflict between the two nations [99]. At the time of the IRA referendum, the Iroquois believed in “collective league sovereignty” [100]. Their governing style was based on “consensus and collective decision-making,” and was “deeply rooted in communal values, kinship ties, and an extensive network of clan-based relationships” [101]. There were and still are two different Iroquois leagues in New York: “one centered in Onondaga… and the other at the Six Nations Reserve” [102]. These two leagues are culturally unified, but function separately in matters of daily life. In the case of serious incidents, the Six Nations Confederacy reserves the right to “speak for all Iroquois tribes, even those not represented in council in Onondaga” to any other governing body [103]. 

The Navajo people were also against the IRA, and were the single most vocal tribe to speak out against the act. The Navajo was the largest tribe in terms of population to oppose the act, perhaps accounting for the saved records and quantity of secondary scholarship on their rejection process. The Hopi, Northern, Eastern, Southern, and Western Navajo tribes were most opposed to the IRA for its herd reduction policies mandated in Section VI [104]. The Navajo people relied heavily on their sheep, goats, horses, and cattle for their livelihoods, and rejected the IRA in hopes of freeing themselves from Collier’s plan to “slash herds” [105]. Collier’s motive for herd reduction was to prevent further erosion of Navajo reservation lands that had been caused by a combination of soft rocks, flash flooding, drought, general climate change, and overgrazing [106]. Collier and the Bureau of Indian Affairs at large failed to acknowledge the cultural impact that herd reduction would have on the Navajo people. 

The Navajo people had faced horrific trauma at the hands of the United States military in 1863 when the government aimed to “punish” Navajo tribes for their aggression towards white settlers [107]. With over six hundred soldiers from the New Mexico Volunteers, Colonel Kit Carson “penetrated into the heart of the Navajo country and applied a ‘scorched earth’ policy to livestock, grain, and orchards” [108]. After six months of constant burning, the horrified and starving Navajo surrendered to Colonel Carson, and the vast majority of living Navajos were taken as prisoners [109]. As prisoners, the Navajo were forcibly removed up to four hundred fifty miles from their ancestral homelands to a reservation in Fort Sumner, New Mexico [110]. For many Natives, Fort Sumner reservation was nothing less than an internment camp [111]. While only one of the goals of the federal government here was herd reduction, the 1863 attack and removal is often cited as the first Navajo herd reduction. With this scarring experience in mind, the Navajo people were highly suspicious of the federal government, and did not want them interfering with their livestock and livelihoods again. 

Additional discontent with the IRA arose in some tribes who had voted for the act during the referendum process in regards to governmentally appropriated funds. Many of the eligible tribes had voted in favor of the IRA in hopes of receiving governmental aid, for their tribal governments, education, general resources, etc. However, it soon became apparent that “Congress never appropriated the full amounts authorized in the Indian Reorganization Act for the purchase of new lands, for the political organization of the tribes, or for the credit loan program” [112]. The failure to appropriate the funds enumerated in the IRA was the result of conservative “western congressmen” who were greatly opposed to “the expenditure of federal funds which would enable Indians to buy the land of whites” [113]. Though these congressmen were unable to prevent the passage of the IRA itself, they did exert the power they had in the “appropriations subcommittee which reviewed the Interior Department budget” [114]. As a result, Native communities, even those who had willingly adopted the act, felt cheated by the federal government, and questioned its ability to grant other rights and provisions granted in the IRA. 

Any change to federal Indian policy or further measures of resistance against the act were greatly halted with the onset of WWII. Following the war, many people continued to oppose Native federal policies and protest for increased civil rights and liberties for Native peoples. The Red Power movement, a civil rights movement for Native Americans, started with Native youths who wished to raise awareness of the unique issues faced by Natives as a result of maltreatment by the United States government since its creation. The Red Power movement largely focused on the genocidal practices of Indian removal and federal Indian boarding schools, and protested contemporary legislation, including the 1972 Indian Education Act, the 1975 Self- Determination Act, and the 1975 Education Assistance Act. 

While the IRA was not the most pressing piece of Native legislation for the Red Power Movement, resistance towards the act endured, this time in the judicial sector. In 1979, the Mashpee Wampanoag tribe of Massachusetts filed a civil lawsuit against New Seabury Corp., a real estate and resort developing business. The Mashpee peoples had lived in eastern Massachusetts, specifically in the town of their namesake for centuries. Non- Mashpee people of the town were well aware of the tribes’ ancestral homelands, and respected sole tribal use and access to them, leaving Mashpee lands largely untouched by non- Native peoples [115]. However, in the 1960s and 1970s, Cape Cod gained popularity as a tourist location, and “developers began buying up the land surrounding the community,” thus threatening the Mashpee community [116].

With this threat to their lands, the Mashpee “attempted to reclaim ancestral homelands” [117]. The tribe filed suit against “developers and private landowners… [for] 11,000 acres of primarily undeveloped land… in and around Mashpee” [118]. The Mashpee Tribe also held that the contested lands were first taken from the tribe “between 1834 and 1870 without the required federal consent,” which violated the Nonintercourse Act of 1790 [119]. The Mashpee Tribe v. New Seabury Corps. was heard in the first federal district court of Massachusetts and “hinged on questions of identity,” because the Mashpees were not a federally recognized tribe and did not have a preexisting treaty with the federal government [120]. The first district court ruled against the Mashpee community, arguing that without tribal recognition, they had no legal stakes to the land [121]. 

After the federal denial of lands, the Mashpee community sought federal recognition in hopes of regaining the lands they had lost. Through a lengthy process, the Mashpee Tribe finally received federal recognition in 2007 [122]. Two years following their federal recognition, the Governor of Rhode Island, Donald Carcieri, filed a civil suit against Ken Salazar, the Secretary of the Department of the Interior on behalf of the Narragansett tribe. Seeking to place some ancestral lands in trust, the Narragansett tribe appealed to the federal government to reassess their position under the IRA. The Department of the Interior denied the Narragansett request. In 2009 the Supreme Court was tasked with determining whether or not the Narragansett tribe fit the definitions of Indian, as stated in Section XIX of the IRA. The Supreme Court ruled that because the Narragansett tribe could not prove that it was under federal jurisdiction on June 1, 1934, they did not qualify for the benefits of the IRA when it was initially ratified, and in 2009. While the Narragansett tribe did not win their case, this retroactive review of the tribe’s status in 1934 allowed the Mashpee Tribe to appeal the decision made by the district court in 1979. The Mashpee were able to prove that they were under the jurisdiction of the federal government on June 1, 1934, thus fulfilling the second definition of Indian as stated in Section XIX of the IRA. With the precedent set in Carcieri v. Salazar, and greatly aided by their recent federal recognition, the Mashpees appealed to the Department of the Interior, and were able to secure a Record of Decision for “Trust Acquisition and Reservation Proclamation” [123]. In 2015, the Department of the Interior took into trust “151 acres in the City of Taunton, Massachusetts, and 170 acres in the Town of Mashpee, Massachusetts for the Mashpee Wampanoag Tribe” [124].

The following year, a civil suit was filed against the Department of the Interior by citizens of Taunton, Massachusetts, claiming that they “were injured by the acquisition and planned development” of the Mashpee land in trust in Taunton [125]. In the United States District Court of Massachusetts, Littlefield challenged the Mashpee’s fulfillment of the second definition of Indian, arguing that the Mashpee did not actually qualify as Indians, and thus had no right to the land placed in trust by the Department of the Interior in 2015 [126]. The district court sided with Littlefield, arguing that the “Secretary [of the Interior] lacked authority to acquire the land in trust” for the Mashpee Tribe [127]. Following this 2016 decision, development of the land in trust was halted, and the decision was referred to the Secretary of the Interior for additional review; “the court explained that on remand DOI could either consider the Mashpee Tribe's eligibility under the first definition of “Indian” or reassess its eligibility under the second definition consistent with the court's interpretation” [128]. 

In 2018, the Department of the Interior upheld the decision of the district court in 2016, and “issued a Record of Decision in which [the Secretary of the Interior] concluded that the Tribe was not “under federal jurisdiction” as of 1934, so did not meet either the first or second definition of “Indian” in the IRA” [129]. This Record of Decision held that the evidence that Mashpee children (enrolled members) had attended federal Indian boarding schools, such as the Carlisle Institute, was more than sufficient in proving federal recognition of the tribe before 1934 [130]. The Mashpee Tribe challenged this Record of Decision in 2018, but were unsuccessful. They filed another case in 2020 against Secretary Bernhardt in Mashpee Wampanoag v. Bernhardt, this time in the D.C. District Court. “The D.C. District Court held that the 2018 ROD was “arbitrary and capricious” under the Administrative Procedure Act (APA), remanded the decision to DOI for reconsideration, and temporarily enjoined DOI from taking the land out of trust” [131]. The D.C. District court stated that the evidence presented to the Secretary of the Interior to prove that the Mashpee Tribe was under federal jurisdiction in 1934 was more than sufficient. Congress then passed two acts to further protect the Mashpee Tribe in 2020: 

H. Amdt. 855 to H.R. 7608, would deny DOI funding to revoke trust status, reservation status, or gaming eligibility for the Mashpee Tribe’s land, and the other, H.R. 312, would ratify the Mashpee Tribe’s trust land and reservation status, dismiss the court cases, and declare the IRA applicable to the Tribe. [132] 

After over forty years of conflict with the federal government, the Mashpee Tribe finally received the legal recognition necessary to secure and protect their ancestral lands. 

Though passed in 1934, the Indian Reorganization Act is still applicable today, as seen above. A largely destructive and widely opposed piece of legislation by Native communities, the IRA failed to fulfill the lofty goals its John Collier had originally promised. Initial Native resistance to the act included tribal rejections during the referendum process and the formation of oppositional inter tribal organizations. Native Americans further resisted the IRA through lawsuits filed in federal courts against both local and federal administration. Native Americans continue to fight for rights to their expression of cultural, religious practices, and as seen in this paper, the rights to their ancestral homelands. The study of the history of federal Indian policy is essential to gaining a more comprehensive understanding of the conditions of Native American peoples in the modern American polity.

Endnotes

 [1] Ronald N. Satz, “‘Tell Those Gray Haired Men What They Should Know:’ The Hayward Indian Congress of 1934,” The Wisconsin Magazine of History 77, no.3 (1994): 197, http://www.jstor.org/stable/.

[2] Satz, “‘Tell Those Gray Haired Men What They Should Know…,’” 197. 

[3] “President Andrew Jackson’s Message to Congress ‘on Indian Removal’ (1830),” National Archives and Records Administration, May 10, 2022. https://www.archives.gov/ milestone- documents/jacksons message-to-congress-on-indian-removal.

[4] “President Franklin Delano Roosevelt and the New Deal: Great Depression and World War II, 1929-1945: U.S. History Primary Source Timeline: Classroom Materials at the Library of Congress: Library of Congress,” https://www.loc.gov/classroom-materials/united-states-history-primary source-timeline/great-depression-and-world-war-ii-1929-1945/franklin-delano-roosevelt-and-the-new deal/.

[5] “The Expedition’s Impact on Indigenous Americans (U.S. National Park Service),” National Parks Service (2023), https://www.nps.gov/articles/the-expeditions-impact.htm. 

[6] “Research Guides: Indigenous Futures: Native Americans: Legislative Acts of Colonial Land Appropriation,” Legislative Acts of Colonial Land Appropriation, (2022), https://lib. guides.umd. edu/c.php?g=1261350&p=9246797. 

[7 ] Leonard A. Carlson, “Federal Policy and Indian Land: Economic Interests and the Sale of Indian Allotments, 1900-1934,” Agricultural History 57, no. 1(1983): 33, http://www.jstor.org/stable/3742657. 

[8] Carlson, “Federal Policy and Indian Land….,” 33.

[9] Sabine Meyer, Native Removal Writing: Narratives of Peoplehood, Politics, and Law (2022): 68, Norman: University of Oklahoma Press (2022). 

[10] Teal Weston, “Research Guides: Dawes Act and Commission: Topics in Chronicling America: Introduction,” https://guides.loc.gov/chronicling-america-dawes-act-commission. 11 Meyer, Native Removal Writing: Narratives of Peoplehood, Politics, and Law, 68.

[12] Carlson, “Federal Policy and Indian Land….,” 33. 

[13] Carlson, “Federal Policy and Indian Land….,” 34. 

[14] Meyer, Native Removal Writing: Narratives of Peoplehood, Politics, and Law, 69.

[15] Janet A. McDonnell, The Dispossession of the American Indian, 1887-1934 (1991): 123, Bloomington, Indiana: Indiana University Press. 

[16] McDonnell, The Dispossession of the American Indian, 1887-1934, 123.

[17] McDonnell, The Dispossession of the American Indian, 123. 

[18] McDonnell, The Dispossession of the American Indian, 123. 

[19] Carlson, “Federal Policy and Indian Land….,” 35. 

[20] McDonnell, The Dispossession of the American Indian, 122. 

[21] Vine Deloria Jr., The Indian Reorganization Act: Congresses and bills, 28, Norman, OK: University of Oklahoma Press (2002).

[22] Deloria, The Indian Reorganization Act: Congresses and Bills, 28. 

[23] Deloria, The Indian Reorganization Act: Congresses and Bills, 28. 

[24] McDonnell, The Dispossession of the American Indian, 124. 

[25] “Native American Collections at The Bancroft Library,” Organization Records - Native American Collections at The Bancroft Library - Library Guides at UC Berkeley, October 8, 2024, https://guides. lib.berkeley.edu/BancroftNativeAmericanCollections/OrgRecords. 

[26] “Native American Collections at The Bancroft Library.”

[27] Khalil Anthony Johnson Jr., "Problem Solver or 'Evil Genius': Thomas Jesse Jones and The Problem of Indian Administration," Journal of the Native American and Indigenous Studies Association 5, no. 2 (2018), Gale In Context: U.S. History (accessed May 7, 2024). https://link.gale.com/apps/doc /A59882 7184/UHIC?u=manc23575&sid=bookmark-UHIC&xid=2df37eb4.; “Meriam Report on Indian Administration and the Survey of Conditions of the Indians in the US,” Library of Congress, https://www. gale.com/binaries/content/assets/gale-us-en/primary-sources/archives-unbound/primary-sources_archives unbound_meriam-report-on-indian-administration-and-the-survey-of-conditions-of-the-indians-in-the-u.s. pdf. 

[28] “Meriam Report on Indian Administration and the Survey of Conditions of the Indians in the US.” 29 “Meriam Report on Indian Administration and the Survey of Conditions of the Indians in the US.” 

[29] “Meriam Report on Indian Administration and the Survey of Conditions of the Indians in the US.” 

[30] “President Franklin Delano Roosevelt and the New Deal: Great Depression and World War II, 1929-1945: U.S. History Primary Source Timeline: Classroom Materials at the Library of Congress: Library of Congress,” https://www.loc.gov/classroom-materials/united-states-history-primary source-timeline/great-depression-and-world-war-ii-1929-1945/franklin-delano-roosevelt-and-the new-deal/.

[31] “President Franklin Delano Roosevelt and the New Deal: Great Depression and World War II, 1929-1945: U.S. History Primary Source Timeline: Classroom Materials at the Library of Congress: Library of Congress,” https://www.loc.gov/classroom-materials/united-states-history-primary-source timeline/great-depression-and-world-war-ii-1929-1945/franklin-delano-roosevelt-and-the-new-deal/.

[32] “Indian Reorganization Act (Indian New Deal) | Colorado Encyclopedia,” Indian Reorganization Act (Indian New Deal), https://coloradoencyclopedia.org/article/indian-reorganization-act-indian-new-deal. 

[33] Deloria, The Indian Reorganization Act: Congresses and Bills, 8- 19. The number of pages given here is based on the length of the act as presented in the here-cited scholarship.

[34] Deloria, The Indian Reorganization Act: Congresses and Bills, xi. 

[35] Deloria, The Indian Reorganization Act: Congresses and Bills, xi. 

[36] Satz, “‘Tell Those Gray Haired Men What They Should Know…,’” 197. 

[37] Satz, “‘Tell Those Gray Haired Men What They Should Know…,’” 199. 

[38] Douglas Nash, “Review of The Indian Reorganization Act: Congresses and Bills Edited by Vine Deloria Jr.,” Digital Commons @ University of Nebraska Lincoln (2004), https://digitalcommons.unl. edu/cgi/viewcontent.cgi?article=1703&context=greatplainsresearch.

[39] Deloria, The Indian Reorganization Act: Congresses and Bills, vii.

[40] Deloria, The Indian Reorganization Act: Congresses and Bills, v. 

[41] Deloria, The Indian Reorganization Act: Congresses and Bills, 27. 

[42 Deloria, The Indian Reorganization Act: Congresses and Bills, 27. 

[43 Deloria, The Indian Reorganization Act: Congresses and Bills, 27.

[44 Deloria, The Indian Reorganization Act: Congresses and Bills, 27. Native children attending the Santee Mission School, a federal Indian boarding school located in Santee, Nebraska, had been tasked withtranslating the bill from English for those who had attended the Rapid City congress.

[45 Deloria, The Indian Reorganization Act: Congresses and Bills, 119.

[46 Lawrence C. Kelly, “The Indian Reorganization Act: The Dream and the Reality,” Pacific Historical Review 44, no. 3 (1975): 297, https://doi.org/10.2307/3638029. 

[47 Kelly, “The Indian Reorganization Act: The Dream and the Reality,” 297. 

[48 Kelly, “The Indian Reorganization Act: The Dream and the Reality,” 297.

[49 Deloria, The Indian Reorganization Act: Congresses and Bills, 12. 

[50 Kelly, “The Indian Reorganization Act: The Dream and the Reality,” 297. 

[51 Kelly, “The Indian Reorganization Act: The Dream and the Reality,” 297. 

[52 Kelly, “The Indian Reorganization Act: The Dream and the Reality,” 298. 

[53 Deloria, The Indian Reorganization Act: Congresses and Bill, 20-23. The number of pages given here is based on the length of the act as presented in the here-cited scholarship. 

[54 Felix Solomon Cohen, Felix S. Cohen’s Handbook on Federal Indian Law, (1982): 147, Charlottesville, Virginia: The Michie Company.

[55 Cohen, Felix S. Cohen’s Handbook on Federal Indian Law, 147. 

[56 Indian Reorganization Act (The Wheeler- Howard Act), June 18, 1934. 

[57Indian Reorganization Act (The Wheeler- Howard Act), June 18, 1934. 

[58 Kelly, “The Indian Reorganization Act: The Dream and the Reality,” 304.

[59Indian Reorganization Act (The Wheeler- Howard Act), June 18, 1934. 

[60Indian Reorganization Act (The Wheeler- Howard Act), June 18, 1934. 

[61Indian Reorganization Act (The Wheeler- Howard Act), June 18, 1934. 

[62Indian Reorganization Act (The Wheeler- Howard Act), June 18, 1934. 

[63Indian Reorganization Act (The Wheeler- Howard Act), June 18, 1934.

[64Indian Reorganization Act (The Wheeler- Howard Act), June 18, 1934. 

[65Indian Reorganization Act (The Wheeler- Howard Act), June 18, 1934. 

[66Indian Reorganization Act (The Wheeler- Howard Act), June 18, 1934. 

[67Indian Reorganization Act (The Wheeler- Howard Act), June 18, 1934. 

[68Indian Reorganization Act (The Wheeler- Howard Act), June 18, 1934. 

[69Indian Reorganization Act (The Wheeler- Howard Act), June 18, 1934. 

[70 David DeJong, “John Collier: Commissioner of Indian Affairs (April 21, 1933–January 22, 1945),” In Paternalism to Partnership: The Administration of Indian Af airs, 1786–2021, (2021): 273, University of Nebraska Press, 2021, http://www.jstor.org/stable/j.ctv2cw0sp9.46; Kelly, “The Indian Reorganization Act: The Dream and the Reality,” 301.

[71 Marci Barnes Gracey, “American Indian Federation,” The Encyclopedia of Oklahoma History and Culture, https://www.okhistory.org/publications/enc/entry?entry=AM006. 

[72 Hauptman, “The American Indian Federation and the Indian New Deal: A Reinterpretation,” 378.

[73 Hauptman, The Iroquois and The New Deal, 2. 

[74 Gracey, “American Indian Federation.” 

[75 Joseph Bruner, Letter to President Franklin Roosevelt, “The American Indian Federation,” Hein Online, August 3, 1936.

[76 Hauptman, “The American Indian Federation and the Indian New Deal: A Reinterpretation,” 379- 380.

[77 Hauptman, “The American Indian Federation and the Indian New Deal: A Reinterpretation,” 383.

[78 Hauptman, “The American Indian Federation and the Indian New Deal: A Reinterpretation,” 382. 

[79 Hauptman, “The American Indian Federation and the Indian New Deal: A Reinterpretation,” 378.

[80 Hauptman, “The American Indian Federation and the Indian New Deal: A Reinterpretation,” 399.

[81 Hauptman, “The American Indian Federation and the Indian New Deal: A Reinterpretation,” 399.

[82 Hauptman, “The American Indian Federation and the Indian New Deal: A Reinterpretation,” 399.

[83 Hauptman, “The American Indian Federation and the Indian New Deal: A Reinterpretation,” 399. 

[84 Kelly, “The Indian Reorganization Act: The Dream and the Reality,” 301.

[85 Kelly, “The Indian Reorganization Act: The Dream and the Reality,” 301. 

[86 Kelly, “The Indian Reorganization Act: The Dream and the Reality,” 302. 

[87 Kelly, “The Indian Reorganization Act: The Dream and the Reality,” 301. 

[88 Kelly, “The Indian Reorganization Act: The Dream and the Reality,” 301. 

[89 Satz, “‘Tell Those Gray Haired Men What They Should Know…,’” 198.

[90 John Collier, Rites and Ceremonies of the Indians of the Southwest (1993): 51, New York, New York: Barnes & Noble Books. 

[91 Satz, “‘Tell Those Gray Haired Men What They Should Know…,’” 197. 

[92 Kelly, “The Indian Reorganization Act: The Dream and the Reality,” 301. 

[93 Kelly, “The Indian Reorganization Act: The Dream and the Reality,” 302. 

[94 "Indians Oppose Act: Four State Tribes Reject the Wheeler- Howard Plan,” New York Times (1935), https://geisel.idm.oclc.org/login?url=https://www.proquest.com/ newspapers/indians-oppose-act/docview/ 

[95 "Indians Oppose Act: Four State Tribes Reject the Wheeler- Howard Plan.”

[96 "Indians Oppose Act: Four State Tribes Reject the Wheeler- Howard Plan.” 

[97 Charles H. Berry, “Record Group 75: Records of the Bureau of Indian Affairs, Administrative Files, 070 Indian Customs.” National Archives and Records Administration, National Archives Catalog.

[98 "Indians Oppose Act: Four State Tribes Reject the Wheeler- Howard Plan.” 

[99 Laurence M. Hauptman, “The American Indian Federation and the Indian New Deal: A Reinterpretation,” Pacific Historical Review 52, no. 4 (1983): 2, https://doi.org/10.2307/3639073.

[100 Hauptman, The Iroquois and The New Deal, 2. 

[101 James Tindle, “The Iroquois Confederacy and Its Influence on American Democracy,” Teachers Institute for Tulsa, October 22, 2024, https://sites.utulsa.edu/teachers/unit/the-iroquois- confederacy and-its-influence-on-american-democracy/. 

[102 Hauptman, The Iroquois and The New Deal, 2.

[103 Hauptman, The Iroquois and The New Deal, 3. 

[104 Marsha Weisiger, “Gendered Injustice: Navajo Livestock Reduction in the New Deal Era,” Western Historical Quarterly 38, no. 4 (2007): 437, https://doi.org/10.2307/25443605. 

[105 Weisiger, “Gendered Injustice: Navajo Livestock Reduction in the New Deal Era,” 437.

[106 Weisiger, “Gendered Injustice: Navajo Livestock Reduction in the New Deal Era,” 439.

[107 Donald Lee Parman, The Navajos and the New Deal, (1976): 7, New Haven, Connecticut: Yale University Press. 

[108 Parman, The Navajos and the New Deal, 8.

[109 Parman, The Navajos and the New Deal, 8. 

[110 “The Long Walk: The Navajo Treaties,” Smithsonian National Museum of the American Indian (2019), https://americanindian.si.edu/nk360/navajo/long-walk/long-walk.cshtml. 111 “The Long Walk: The Navajo Treaties.” 

[112 Kelly, “The Indian Reorganization Act: The Dream and the Reality,” 306. 

[113 Kelly, “The Indian Reorganization Act: The Dream and the Reality,” 306. 

[114 Kelly, “The Indian Reorganization Act: The Dream and the Reality,” 306.

[115 “Identity and Tribal Recognition: The Mashpee Community,” Harvard University “Pluralism Project,” https://pluralism.org/identity-and-tribal-recognition-the-mashpee-community#:~:text=The%20Federal%2 0District%20court%20case%20of%20Mashpee%20Tribe%20v.%20New. 

[116 “Identity and Tribal Recognition: The Mashpee Community,” 2. 

[117 Shelby Johnson, “Histories Made Flesh: William Apess’s Juridical Theologies,” MELUS 42, no. 3 (2017): 6–25, https://www.jstor.org/stable/26566066.

[118 “Identity and Tribal Recognition: The Mashpee Community,” 2. 

[119 Johnson, “Histories Made Flesh: William Apess’s Juridical Theologies,” 6. 

[120 “Identity and Tribal Recognition: The Mashpee Community,” 2. 

[121 “Identity and Tribal Recognition: The Mashpee Community,” 3. 

[122 “Mashpee Wampanoag Tribe v. David Littlefield, et al., Defendant-Intervenors,” (2020) Find Law, June 5, 2020. https://caselaw.findlaw.com/court/us-dis-crt-dis-col/2070098.html. 

[123 “Mashpee Wampanoag Tribe v. David Littlefield, et al., Defendant-Intervenors,” 3.

[124 “Mashpee Wampanoag Tribe v. David Littlefield, et al., Defendant-Intervenors,” 3.

[125 “Mashpee Wampanoag Tribe v. David Littlefield, et al., Defendant-Intervenors,” 3.

[126 “Mashpee Wampanoag Tribe v. David Littlefield, et al., Defendant-Intervenors,” 3.

[127 “Mashpee Wampanoag Tribe v. David Littlefield, et al., Defendant-Intervenors,” 3. 

[128 “Mashpee Wampanoag Tribe v. David Littlefield, et al., Defendant-Intervenors,” 3.

[129 “Mashpee Wampanoag Tribe v. David Littlefield, et al., Defendant-Intervenors,” 3.

[130 M. Maureen Murphy, “Mashpee Wampanoag v. Bernhardt: A Tale of Two Definitions of Indian,” Legal Sidebar, August 17, 2020, https://crsreports.congress.gov/product/pdf/LSB/LSB10533.

[131 Murphy, “Mashpee Wampanoag v. Bernhardt: A Tale of Two Definitions of Indian,” 3.

[132 Murphy, “Mashpee Wampanoag v. Bernhardt: A Tale of Two Definitions of Indian,” 3. 

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