Protecting Native Lands:

Self-Identification, Legal Action and the Case of Devil’s Tower

by Jane PojawaCalifornia State Polytechnic University, Pomona

jmpojawa@csupomona.edu

Ethnic and Women’s Studies 403, Native American Contemporary IssuesDr. Sandy Kewanhaptewa-DixonFall 2013, Term Paper and Final Presentation

Native American spiritual beliefs and practices are tied to the

land on which ceremonies are performed. Unfortunately, many

of those sites are in danger because of limited access, develop-

ment, and vandalism. Saving these sacred sites is critical to the preserva-

tion of indigenous culture and also for the preservation of world heritage

and our nation’s natural beauty and diversity of species. A loss of sacred

lands is a loss for all people, not solely Native Americans. How we meet

this challenge will determine how humanity goes forward. Will we preserve

the environment and honor its contribution to our culture or will we put the

short-term gain of a few corporations and thrill-seekers ahead of the com-

mon good?

Contents:Native American Identity . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2

The American Indian Religious Freedom Act . . . . . . . . . . . . . . . . . 4

The First Amendment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5

The United Nations Declaration on the Rights of Indigenous Peoples . . . . 7

Case Study: The Devil’s Tower . . . . . . . . . . . . . . . . . . . . . . . . . 8

Statement by the Becket Fund . . . . . . . . . . . . . . . . . . . . . . . . . . . 9

Keystone XL Pipeline . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11

References . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13

PROTECTING NATIVE LANDS�

Native American Identity

To address these questions, we will examine the American Indian Religious Freedom Act and the case of

Devil’s Tower. But first, we will address the issue of Native American identity. According to the United States

Census, there are more American Indians now than at any time since the 1890s. This is because the census has

changed and so have attitudes.

Prior to the 1960s, census re-

spondents did not self-identify

their race; the census taker filled

in the blank based on what he

thought you “looked like.” In

2000, the census was modified

to accommodate respondents

who self-identified with more

than one race.

According to the Office

of Management and Budget,

“American Indian or Alaska Na-

tive” refers to a person having

origins in any of the original

peoples of North and South

America (including Central

America) and who maintains

tribal affiliation or community

attachment. Prior to the 2000

census, people who self-identi-

fied as American Indian were

asked to provide documentation

Cloud Man was 100 percent Assinaboine Sioux, could document it, and would have no problem figuring out which box to check on a census form. Things are more complicated now; many people have mixed an-cestry or belong to tribes that are not recognized by state or federal governments - Photo: Frank A. Rinehart, 1898.

PROTECTING NATIVE LANDS �

to prove a tribal affiliation. (Hitt) By 2010, respondents could “choose”

to be American Indian, and the numbers went up.

In the 2010 Census, 5.2 million people in the United States iden-

tified as American Indian and Alaska Native, either alone or in combina-

tion with one or more other races. Out of this total, 2.9 million people

identified as American Indian and Alaska Native alone. Almost half of

the American Indian and Alaska Native population, or 2.3 million people,

reported being American Indian and Alaska Native in combination with

one or more other races. The American Indian and Alaska Native in com-

bination population experienced rapid growth, increasing by 39 percent

since 2000. (U.S. Census Bureau)

That’s a lot of people, but not enough to be a deciding factor in

an election. The census report goes on to say, “The U.S. population on

April 1, 2010, was 308.7 million. Out of the total U.S. population, 2.9

million people, or 0.9 percent, were American Indian and Alaska Native

alone. In addition, 2.3 million people, or another 0.7 percent, reported

American Indian and Alaska Native in combination with one or more

other races. Together, these two groups totaled 5.2 million people. Thus, 1.7 percent of all people in the United

States identified as American Indian and Alaska Native, either alone or in combination with one or more other

races… The total U.S. population grew by 9.7 percent, from 281.4 million in 2000 to 308.7 million in 2010. In

comparison, the American Indian and Alaska Native alone population increased almost twice as fast as the total

U.S. population, growing by 18 percent from 2.5 million to 2.9 million.” (U.S. Census Bureau). In addition, 78

percent of Native Americans live outside a reservation. (Yurth)

In other words, thanks to being able to self-report instead of prove tribal affiliation, being a member of

more than one race, and a general shift in societal attitude about the stigmatization of Native Americans (It’s

ok to be Indian), Native Americans are the fastest-growing ethnic group in the United States. That is very good

news from a populist standpoint, and is sure to be a factor in the preservation of heritage and sacred sites, but

Native Americans only account for a little less than 2 percent of the total US population. They need allies.

Jim Ruel, a comedian, is a mem-ber of the Bay Mills Band of Ojibwe on his mother’s side. His father is white. He grew up in Milwaukee, not on a reservation. Because he is mixed-race and doesn’t “look Indian” he and his siblings might have had problems filling out a census form accurately prior to �010.

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The American Indian Religious Freedom Act

The first section of the American Indian Religious Freedom Act (AIRFA) reads “On and after August

11, 1978, it shall be the policy of the United States to protect and preserve for American Indians their inher-

ent right of freedom to believe, express, and exercise the traditional religions of the American Indian, Eskimo,

Aleut, and Native Hawaiians,

including but not limited to ac-

cess to sites, use and possession of

sacred objects, and the freedom to

worship through ceremonials and

traditional rites.” (The American

Indian Religious Freedom Act,

Public Law No. 95-341, 92 Stat.

469 (Aug. 11, 1978)).

It was a very promising

start in redressing the horrific

abuse suffered by Native Ameri-

cans in trying to practice their reli-

gion and culture over the previous

300 years. It passed both houses

and was signed into law by Presi-

dent Jimmy Carter after a congres-

sional report found that “state and

federal laws continued to hamper

and interfere with Native American

religious practices.” Unfortunately,

it is a law without teeth. There’s no

penalty for impinging on these reli-

Native American prisoners in every state fought long and hard for recognition of their religious rights. Prisoners here are leaving the sweat lodge at San Quentin in California. - Photo: Nancy Mullane

PROTECTING NATIVE LANDS �

gious freedoms, which should be protected under

the First Amendment regardless.

This law has been periodically revisited

and strengthened. The Native American Graves

Protection and Repatriation Act (NAGPRA)

added needed protections for native religions in

concrete and practical ways. In 1994, Congress

gave Native Americans the “right” to use peyote.

Peyote, a cactus with hallucinogenic qualities,

has been used ceremonially for around 10,000

years and only became illegal in the 1970s. Also

in 1994, a presidential memorandum recognized

the sacred significance of eagle feathers in Na-

tive American culture and religious practices and

provided easier access to scarce eagle carcasses

as well as an exception for possession of feathers

from these critically endangered birds. On May

31, 2005, the Supreme Court ruled in the case of

Cutter v Wilkinson that “local, state, and federal

prisons must meet inmates’ needs to carry out

their spiritual lives and practice their religions.”

The decision upheld the Religious Land Use

and Institutionalized Persons Act of 2000 (RLUIPA)

which holds that Native Americans have a right to practice their religion even when incarcerated. (Protecting

Religious Freedom and Sacred Sites) This is a boon because so many Native Americans are incarcerated.

The incarceration rate of Native Americans is 38 percent higher than the national rate. In South Dakota,

Native Americans make up 8 percent of the state’s population, but they comprise 22 percent of the state’s male

prison population and 35 percent of female prison population, according to a Dakota-Lakota-Nakota Human

The First Amendment and Why it Matters:

The FirsT AmendmenT: “Congress shall make no law respecting an establishment of religion, or prohibit-ing the free exercise thereof; or abridging the freedom of speech, or of the press; or the right of the people peaceably to assemble, and to petition the Government for a redress of grievances.”

Groups wanting to block Native American access and stewardship of sacred sites often invoke the “Es-tablishment Clause” of the First Amendment claiming that Congress is “establishing a religion” by support-ing these claims. The “Establishment Clause” is fol-lowed by the “Free Exercise Clause,” based on the phase “prohibiting the free exercise thereof.”

In other words, this is the basis of the separation between church and state.

To expand on this idea, “The Establishment Clause has generally been interpreted to prohibit 1) the estab-lishment of a national religion by Congress, or 2) the preference by the U.S. government of one religion over another. The first approach is called the “separation” or “no aid” interpretation, while the second approach is called the “non-preferential” or “accommodation” interpretation. The accommodation interpretation pro-hibits Congress from preferring one religion over an-other, but does not prohibit the government’s entry into religious domain to make accommodations in order to achieve the purposes of the Free Exercise Clause.”

Lee v. Weisman, 112 S. Ct. 2649, 2667 (1992) (Justice Souter, joined by Justices Stevens and O’Connor, concurring). - See more at: http://consti-tution.findlaw.com/amendment1/annotation01.html#f12

PROTECTING NATIVE LANDS�

Rights Advocacy Coalition Report. Additionally, “Law enforcement agents arrest American Indians and Alas-

kan Natives at twice the rate of the greater U.S. population for violent and property crimes. On average, Ameri-

can Indians receive longer sentences than non-Indians for crimes. They also tend to serve longer time in prison

for their sentences than non-Native Americans. The suicide rate is higher among American native inmates

incarcerated in jails than non-Indians.” (Bell) My personal experience with a local sweat lodge has shown how

critical spiritual practice and native community is to inmates and to prevent recidivism.

But despite these modest gains, the overall picture has been bleak. The Friends Committee on National

Legislation, a Quaker advocacy organization for religious freedom expressed the shortfall in heart-wrenching

terms:

The Vulnerability of Native Sacred Sites: Unfortunately, the courts and Congress have com-

pletely failed to enforce AIRFA’s promise to protect and guarantee access to sacred sites. The lack of

legal protection for native sacred sites is a continuing and painful void in the policy to preserve Native

American’s religious freedom and practices. In 1989, the Supreme Court ruled that neither AIRFA nor

the First Amendment of the Bill of Rights legally protect Native American’s holiest places. In its land-

mark decision in Lyng v Northwest Indian Cemetery Protective Association, the court found that private,

corporate, and governmental land holders’ rights to

build and develop on their properties superseded the

rights of American Indians’ freedom religion, even

though the actions of land owners “could have devas-

tating effects on traditional Indian religious practic-

es.” In 1996, President Clinton issued a Presidential

Memorandum that requires federal agencies to “avoid

adversely affecting the physical integrity” and “ac-

commodate access to and ceremonial use of” sacred

sites. However, the Lyng decision is legal precedent;

only Congress can rectify the existing gap in protec-

tion for sacred sites. To protect these sites tribes need

legal standard to defend their holy places. Without a

On Oct. 31, 2012, at least six pertoglyphs were cut out of a major rock ceremonial site on the Volcanic Tableland, north of Bishop, California. The petroglyphs are some 3,500 years old, so the artwork on them is irreplaceable and the worship site is irreparapbly damaged.

http://www.nativenewsnetwork.com/sacred-petroglyphs-stolen-from-california-sacred-site.html

PROTECTING NATIVE LANDS �

“cause of action” tribes will continually lose sacred sites to development and religious practices will be

infringed upon. (Protecting Religious Freedom and Sacred Sites)

In 2003, Representative Nick Rahall, Democrat West Virginia, introduced the “Native American Sacred

Lands Act.” (H.R.2419 — 108th Congress (2003-2004)) It would have strengthened the American Indian Reli-

gious Freedom Act considerably and given Native Americans much more say in their own governance as well

as declaring some areas “unsuitable for development” – permanently. Unfortunately, the bill never made it past

the House and it has not been reintroduced.

The United Nations Declaration on the Rights of Indigenous Peoples was adopted by the United Na-

tions General Assembly during its 61st session at UN Headquarters in New York City on 13 September 2007.

143 countries voted to support it, 11 abstained and 4 voted against. Those four - Australia, Canada, New Zea-

land, and United States - were former British colonies and have “large non-indigenous immigrant majorities

and small remnant indigenous populations.” Certainly a large part of the reticence to signing the declaration

was the potential for lawsuits. Since then, all four countries have moved to endorse the declaration. The United

States was the very last, holding out until Dec 9 2010 when President Obama voiced support for indigenous

rights stating “While we

cannot erase the scourges or

broken promises of our past,

we will move ahead together

in writing a new, brighter

chapter in our joint history.”

(Richardson)

A General Assembly Declaration it is not a legally binding instrument under international law, but it

does “represent the dynamic development of international legal norms and it reflects the commitment of the

UN’s member states to move in certain directions.” That direction is towards non-discrimination towards native

people.

Article 11: United Nations Declaration on the Rights of Indigenous Peoples

1. Indigenous peoples have the right to practice and revitalize their cultural traditions and customs. This includes the right to maintain, protect and develop the past, present and future manifestations of their cultures, such as archaeological and historical sites, artifacts, designs, ceremonies, tech-nologies and visual and performing arts and literature. (United Nations Declaration on the Rights of Indigenous Peoples, 9)

PROTECTING NATIVE LANDS8

Case Study: The Devil’s Tower

Devil’s Tower National Monument (DTNM), one of Wyoming’s natural treasures, is a 867-foot-tall

butte of striated volcanic rock that boasts some of the world’s longest and most vertical continuous cracks.

Consequently by the mid-90s it drew upwards of 6,000 technical rock climbers annually, along with hundreds

of thousands of non-climbing tourists. It is also sacred to twenty or so local tribes, as well as being a symbolic

focus for Native Americans and environmentalists everywhere. (Ling)

In a document prepared by the Indian Law Resource Center, the depredations of rock climbers were

significant.

“Devil’s Tower is a sacred site and a vital cultural resource for Indians from over twenty Plains

tribes. For centuries, Indians have performed religious and cultural ceremonies there, including the Sun

Dance, sweat lodge rites, vision quests, and prayer offerings. These ceremonies continue today. How-

ever, in recent years, growing numbers of visitors and rock climbers have disrupted the ceremonies.

According to Arvol Looking Horse, a member and spiritual leader of the Cheyenne River Sioux Tribe

in South Dakota, “Climbers make lots of noise and come near our people when they are praying. By

doing this, they disturb our efforts to obtain spiritual guidance. When climbers hammer objects into the

Mato Tipila is sacred to many of the plains tribes. One creation story is fairly prevalent: several young children were escaping a large, hungry grizzly bear and prayed to Wakan Tanka, the Creator god to save them while they were making a last stand on a rock. The Creator raised the rock up and up, pro-tecting the children, as the bear dug deep gouges into the side, vainly trying to get his meal back. The children, according to which version of the story is being told are rescued by an eagle and returned to their village or become stars in an astronomical formation with inherent significance.

PROTECTING NATIVE LANDS 9

butte, it is like they are pounding stakes into

our bodies.” (Indian Religious Freedom at

Devil’s Tower National Monument.)

Devil’s Tower is on public lands and its

governing body is the National Park Service (NPS).

Eventually, the NPS was forced to come up with a

compromise as tensions grew between tribal groups

and rock climbers and the Native Americans initi-

ated lawsuits.

These suits, plus the allies the Native Amer-

icans were able to rally, which included a number

of religious organizations, prevailed. It isn’t a

perfect solution, but climbing has been somewhat

restricted and native claims to sacred sites have

been upheld. A climbing management plan for

Devil’s Tower National Monument was released in

February 1995.

This plan provided direction for manag-

ing climbing activity at Devil’s Tower in order to

protect the natural and cultural resources present.

A Climbing Management Plan Update (CMP)

was completed in 2006. Primary features of the

CMP Update are an improved climber education

program, safety standards, and climbing access

routes. (National Park Service) The main strides

are that there is a “voluntary” ban on climbing in

the month of June when most of the ceremonies

Statement by the Becket Fund on the Significance of Bear Lodge Multiple

Use Association v. Babbitt and Cheyenne River Sioux Tribe,

Wyoming (1998)

The Becket Fund often pushes back against attempts to abuse the Establishment Clause to stop the gov-

ernment from reasonably accommodating religious be-lief. In this case, several Native American tribes, includ-ing the Cheyenne River Sioux of Wyoming, had worked with the National Park Service to make arrangements to practice their ancient Lakota rituals undisturbed ev-ery June on ground sacred to them at Devil’s Tower National Monument in Wyoming. The area also hap-pens to be quite popular for rock climbers and visitors, so the Park Service implemented a sensible plan that discouraged rock climbing during June, posted signs marking the sacred ground, and started a cultural edu-cation program that informed visitors of Native Ameri-can culture and religion.

But a group of climbing guides sued the Park Ser-vice, arguing that the efforts [in violation of the Estab-lishment Clause] made the Lakota religion an official state religion in Wyoming. The Becket Fund, along with a group of civil liberty and religious organizations, fought back with an amicus brief on behalf of the tribe. We got the case dismissed by the Tenth Circuit Court of Appeals, who found that the climbers had failed to identify a personal injury and consequently had no standing to bring the case.

Cases like this are important to the Becket Fund, because we find it admirable when governments make a conscientious effort to protect religious minorities. The sad truth is that these lawsuits threaten religious expression in scores of other scenarios. The same ar-guments used by the climbers, while seemingly absurd, are used to challenge studying religious texts in high school history or English classes, or exhibiting reli-gious elements in local cultural festivals and displays. If they succeed we will all be the poorer for it.

http://www.becketfund.org/bear-lodge-multiple-use-association-v-bab-bitt-and-cheyenne-river-sioux-tribe-wyoming-1998/

PROTECTING NATIVE LANDS10

are held. None of the commercial guides are allowed

in, and climbing has been reduced by 80 percent in that

month. This also allows for public education about why

the Plains Tribes consider the Tower to be sacred and

why they do not relish rock climbers. In May through

July there are holds on climbing due to nesting prairie

falcons.

There were detractors. After the 1995 poli-

cies went into effect, a group of climbing guides, Bear

Lodge Municipal Use Association, sued the National

Park Service, specifically Bruce Babbitt in his capacity

as Interior Secretary, claiming that the Final Climbing

Management Plan for Devil’s Tower National Monu-

ment violated the Establishment Clause of the Constitu-

tion. The courts upheld the indigenous claims to the Native American Free Exercise of Religion Act of 1978.

(Public Lands Council v. Babbitt, 154 F.3d 1160, 1166 (10th Cir.1998) and Bear Lodge Multiple Use Associa-

tion v. Babbitt (10th Cir. 1999).)

“In its April 26, 1999 ruling, the United States Court of Appeals for the Tenth Circuit upheld the Nation-

al Park Service’s accommodations of American Indian religious practices at Devil’s Tower National Monument.

In March of 2000, the U.S. Supreme Court denied the plaintiffs appeal of the 10th Circuit ruling, thus upholding

the appellate court’s decision as final.” (Ling)

Looking Horse viewed this ruling is a “significant victory.” “Once again, we can worship in our tra-

ditional way and practice our traditional culture without interference at this sacred site.” (Indian Religious

Freedom at Devil’s Tower National Monument.) That assessment may be a little overoptimistic, but it does set

precedents for upholding native rights to sacred space.

As a side note, “Devil’s Tower” is a derogatory term used by white settlers to describe the relationship

of “heathens” to the rock formation. Most native languages associate it with the power of a bear. It is referred to

by many American Indians as “Mato Tipila,” which means “Bear Lodge” in Lakota, or “He Hota Paha,” which

Arvol Looking Horse is the 19th Generation Keeper of the Sacred White Buffalo Calf Pipe and a staunch advocate for the indigenous protection of Mato Tipila and all sacred lands.

http://www.manataka.org/page108.html

PROTECTING NATIVE LANDS 11

means “Grey Horn Butte” in Lakota. It is also called “Bear’s Tipi” in Arapahoe, “Bear’s House” in Crow, and

“Tree Rock” in Kiowa. (Bear Lodge Multiple Use Association v. Babbitt (10th Cir. 1999).)

Case Study: Nebraskans Come Together to Fight Keystone XL Pipeline

Bear Lodge Multiple Use Association v. Babbitt was an exception. Native Americans lose lawsuits as

often as not when trying to protect sacred sites on public lands. Still, resistance is growing stronger and non-na-

tive involvement can be a tipping point. It isn’t that native people need someone to rescue them; on the contrary

Native American lawyers, seasoned activist/protesters, and a deep commitment to a spiritual cause make them

the catalyst in many of these situations

where ordinary citizens must take a

stand against development.

Case in point, native and non-

native Nebraskans have joined forces to

protest the Keystone XL Pipeline:

Jane Kleeb, executive director

of Bold Nebraska, an organization that

opposes the pipeline said “It [the joint

opposition] would have never happened

if TransCanada hadn’t come knocking

on our doors.” Mekasi Horinek, a Ponca

who grew up on the reservation in Okla-

homa where his ancestors were relo-

cated, concurred. “Living on the res, it’s

usually us against them,” he said. “You

kind of grow up with that mentality.” …

Horinek sees that the white ranchers and

landowners, threatened with eminent

From the RT Network: “People opposed to the Keystone XL pipeline gather in prayer in Fullerton, Nebraska. Leaders from 11 Native American tribes stormed out of a meeting with US federal officials in Rapid City, South Dakota, to protest the proposed Keystone XL pipeline, which they say will lead to ‘environmental genocide.’ Native Americans are opposed to the 1,179-mile long Keystone XL project - a system to transport tar sands oil from Canada and the northern United States to refineries in Texas - for various reasons, including potential irreversible damage to sacred sites, pollution, and water contamination. Although the planned pipeline would not pass directly through any Native American reservation, tribes in proximity to the proposed system say it will violate their traditional lands and that the environmental risks of the project are simply too great.” (AFP Photo / Guillaume Mayer)

http://rt.com/usa/native-americans-keystone-pipeline-475/

PROTECTING NATIVE LANDS1�

domain and the loss of the right to their own land, are beginning to understand what the tribes like the

Ponca experienced during colonization. “This pipeline is dividing the land,” he says, “but it’s bringing

people together.” (Moe)

It remains to be seen, of course, whether or not this alliance will be enough to forestall the construction

of the massive pipeline. The fact that there is multicultural cooperation is encouraging. It is also very promising

that native coalitions are fighting everywhere – against fracking, against genetically modified organisms, against

drilling and poaching and above all to protect native lands. By throwing support behind them, we’re making the

world a better place for our children.

One place where Californians can show their support for the protection of sacred lands is by stand-ing with the Winnemem Wintu, the Middle Water People of Lake Shasta who are fighting to keep the waters behind the Shasta Dam from being raised and consequently wiping out their ancestoral village and depleting salmon populations. They are fighting agribusinesses who want more water for crop ir-rigation. A dam raise of about 18-feet, the most likely scenario, would permanently or seasonally flood an estimated 39 sacred sites along the McCloud River, including Puberty Rock, and would essentially end their ability to practice our culture and religion. http://www.winnememwintu.us/tag/shasta-dam/

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Bell, Jamaal. “Mass Incarceration: A Destroyer of People of Color and Their Communities.” The Huffington Post. TheHuffingtonPost.com, 17 May 2010. Web. 27 Nov. 2013. <http://www.huffingtonpost.com/ja maal-bell/mass-incarceration-a-dest_b_578854.html>.

Blatt, W. (2005). Holy River and Magic Mountain: Public Lands Management and the Rediscovery of the “Sacred in Nature”. Law & Society Review, 39(3), 681-688. doi:10.1111/j.1540-5893.2005.00238.x

Huntsinger, L and Fernández-Giménez, M (2000) Spiritual Pilgrims at Mount Shasta, California. Geographical Review, Vol. 90, No. 4, pp. 536-558

Hitt, Jack (August 21, 2005). “The Newest Indians”. The New York Times Magazine.

Hooks, G., & Smith, C. L. (2004). The Treadmill of Destruction: National Sacrifice Areas and Native Americans. American Sociological Review, 69(4), 558-575.

“Indian Religious Freedom at Devil’s Tower National Monument.” indianlaw.org. Indian Law Resource Center, n.d. Web. 26 Nov. 2013. <http://www.indianlaw.org/projects/past_projects/cheyenne_river>.

Linge, G. (2000). Ensuring the Full Freedom of Religion on Public Lands: Devils Tower and the Protection of Indian Sacred Sites. Boston College Environmental Affairs Law Review, 27(2), 307.

Moe, Kristin. (2013) “’Cowboys and Indians’ Camp Together to Build Alliance Against Keystone XL.” YES! Magazine. 22 Nov. 2013. Web. 26 Nov. 2013.

Plaut, E. (2009). Tribal-Agency Confidentiality: A Catch-22 for Sacred Site Management? Ecology Law Quarterly, 36(1), 137-166.

“Protecting Religious Freedom and Sacred Sites.” Friends Committee on National Legislation ., n.d. Web. 27 Nov. 2013. <http://fcnl.org/issues/nativeam/protecting_religious_freedom_and_sacred_sites/>.

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Richardson, Valerie. “Obama adopts U.N. manifesto on rights of indigenous peoples.” Washington Times. The Washington Times, 16 Dec. 2010. Web. 27 Nov. 2013. <http://www.washingtontimes.com/ news/2010/dec/16/obama-adopts-un-manifesto-on-rights-of-indigenous-/?page=all>.

“United Nations Declaration on the Rights of Indigenous Peoples.” Version 07-58681. The United Nations, n.d. Web. 26 Nov. 2013. <http://www.un.org/esa/socdev/unpfii/documents/DRIPS_en.pdf>.

U.S. Census Bureau. (2012, January). The American Indian and Alaska Native Population: 2010: 2010 Census Briefs Retrieved November 26, 2013, from http://www.census.gov/prod/cen2010/briefs/c2010br-10.pdf

Yurth, Cindy. “Census: Native Count Jumps by 27 percent.” Census: Native Count Jumps by 27 Percent. The Navajo Times, 26 Jan. 2012. Web. 26 Nov. 2013. <http://navajotimes.com/news/2012/0112/ 012612census.php#.UpU9ZdKsjTo>.