Portfolio Essay

Quinn Murry

The University of Washington, Seattle

Professor Stephanie Smallwood

13 March 2024
 Introduction

I grew up in Olympia, Washington, twelve miles south of the Nisqually Indian

Reservation. Like most in my community, I recognized that the land was tribal territory and that

that distinction enabled the reservation to have laws and regulations different from those of the

surrounding cities. However, my awareness and curiosity of this disparity extended only to the

outcomes of laws exploited by members of my community – chiefly legalized gambling and the

sale of fireworks. Consequently, I did not consider the causes of the legal variance I noticed, nor

did I inquire about or explore the larger legal differences between the Nisqually reservation and

my Hometown. I certainly did not connect this legal incongruity or the reservations to a still-

ongoing settler colonial process that began hundreds of years ago. However, as our class

discussions and readings engaged with themes of settler colonialism, dispossession, and settler

memory, I became aware of the centrality of laws, particularly those that established the

reservations and later governed the relationships between the US Government, other settler-

colonists, and the treaty signatory tribes, to the settler colonial process and indigenous survival

and resistance despite it. In the U.S. and, in particular, in the state of Washington, the law

served the dual and contrasting purposes of facilitating and legitimizing the settler colonial

dispossession of indigenous peoples and offering an unintended mechanism for indigenous

communities to fight against their continued dispossession. Examination of foundational legal

texts and decisions affecting the Nisqually Tribe, alongside their resistance efforts and crucial

events in the state’s Indigenous history, showcases the dueling aspects of American Indian Law.

Artifact One: The Treaty of Medicine Creek

Predating the Treaty of Medicine Creek, the United States had a history of intentionally

manipulating the international treaty process to self-legitimize and formalize immoral and unjust
processes of colonial dispossession, which stripped tribes of their sovereignty and historical

lands. Treaties were not the first legal processes used by settler colonists to self-legitimize the

dispossession of indigenous persons. The very charters that established the Massachusetts Bay

Colony gave the company legal rights, within the English legal system, to all lands not occupied

by subjects of a Christian ruler and, consequently, unilateral legal jurisdiction over all native

lands in the region (Newell, 2015). Later laws further justified the seizure of land and slaves

from indigenous nations (Newell, 2015). However, the “Indian treaties” were distinct in that they

were the first, and arguably only, bilateral legal agreements between the colonizing force and the

colonizer, which required representatives from both parties to formally acknowledge the transfer

of lands and sovereignty from tribes to the U.S. government.

A review of the Treaty of Medicine Creek – Artifact one, and the 1854 treaty between

Washington Territory Governor Stevens and the Nisqually – tribe reveals the intentional

dispossession central to the foundation of bilateral legal relationship and settler attempts to

justify it. Signatory tribes ceded “relinquish[ed] and convey[ed] to the United States all their

right, title, and interest in and to the lands and country [they] occupied (Kappler, 1904, 661).

This text formalized the dispossession of land. Critically, the treaty required the United States to

pay the tribe a fee for the ceded land. While not commensurate to the value of the land, the

inclusion of a fee provided additional moral justification to settler colonists, enabling the

establishment of settler colonial memory, which portrayed the foundation of reservations as

transactional negotiations rather than violent seizures (Aker, 2014). As Aker notes, treaty usage

allowed the United States to falsely portray itself domestically and abroad as an equitable and

fair expander who negotiated in good faith with the tribes (2014). By signing, the Nisqually also

agreed to “acknowledge their dependence on the Government of the United States” (Kappler,
1904, 661). To the US, this treaty text legally stripped the Nisqually of their sovereignty and

placed them firmly under the jurisdiction of U.S. legal systems while requiring their

acknowledgment of said relationship. Simply put, the U.S. used treaty law to strip tribes like the

Nisqually of their land and subjugate their peoples under a façade of morality, which enabled the

U.S. to project and protect a self-image of decency and fairness while deriving benefits from

unjust and unethical practices.

Artifact(s) Two and Three: Maps of Washington State Tribes

US exploitation of the treaty process to facilitate settler colonialism extended beyond the

dispossession of land and sovereignty as it laid legal foundations for the containment, erasure,

and removal of indigenous communities. In “Settler Colonialism as a Structure,” Evelyn Nakano

Glenn posits that four mechanisms of settler colonialism, containment, erasure, removal, and

terrorism, drive the replacement of populations with a new settler population (2014). Treaties,

like the Treaty of Medicine Creek, provided legal justification for all mechanisms but terrorism.

Concerning containment, the treaties regularly forced numerous tribes into the same reservation

and moved them from large territories to small ones. Artifact two shows a map of tribes and their

statewide dispersion before the first treaty was signed. Artifact three shows their dispersion

currently. By the time all Stevens treaties were signed, statewide tribes had surrendered over

90% of their land and were contained to the reservations shown in Artifact Three (Richards,

2005). This containment was intentionally manufactured and allowed through the treaties, as

Commissioner of Indian Affairs George W. Manypenny instructed Stevens to consolidate tribes

in as few reservations as possible (Richards, 2015). A necessary component of this consolidation

was their removal from their once-occupied lands. The treaty’s requirement that “tribes and
bands agree to remove to and settle [elsewhere]” showcases the legal foundation for Indian

removal (Kappler, 1904, 661).

The treaty process also laid the legal groundwork for the erasure of tribal histories and

identities. Artifact Two shows that before the treaty process, some six dozen (estimated

conservatively) tribes occupied the state. Today, as shown in Artifact Three, only 29 have legal

recognition. The treaty process caused much of this disparity. To negotiate “legally” with tribes,

Governor Stevens appointed prominent members of some tribes as chiefs to serve as signatories

irrespective of their connection to the tribe and labeled some tribes as subjects of others

(Richards, 2005). These subject tribes were effectively erased from law and forced to adopt the

identity of other tribes to incur any of the benefits offered by the treaty alongside its steep costs.

Moreover, not all signatory tribes were granted legal standing by the U.S. government, and many

(including the Duwamish) were split up or merged with other tribes in different reservations

(something allowed by the treaty) (Richards, 2005). As noted by Harmon, the treaties were

deliberate instruments that confirmed the American notions of power, politics, and social

organization (2008). This legalized splitting further contributed to the erasure of pre-existing

tribal identities and replaced them with Americanized identities (Harmon, 2008). Thus, the treaty

and reservation process contributed to the settler colonial progress by legitimizing the removal,

containment, and erasure of tribes.

Artifact Four: The 1871 Indian Appropriations Act

However, while they allowed the concentration, removal, and erasure of many tribes,

Stevens’ and other treaties gave the federally recognized signatory tribes a degree of legitimacy

and rights under U.S. law. The Nisqually and other formed tribes were promised, by the letter of

the law, protection from settlers, retention of land, payments, and fishing and hunting rights.
While far less than what they surrendered, this provision, considered an afterthought and of little

concern to Stevens, would prove critical to future tribal resistance. More importantly, the

treaties, intended to strip away the sovereignty of the tribes by making them a protectorate of the

U.S., had the additional effect of legally recognizing their status as a “distinct, self-governing

people” and as a once-fully sovereign entity (Barrows, 2008). This semi-sovereign status was

quickly seen as contradictory to the interests of the settler colonists. Dispossessed of their land,

the tribes did not view themselves as dispossessed of their sovereignty and acted, as U.S.

Commissioner of Indian Affairs Ely S. Parker noted, with a perceived “false sense of national

independence” (Hirsh, 2014). Political actors across the nation advocated for additional

measures to communicate to the tribes – of which most had not read the treaties they signed

– that they had been dispossessed of their sovereignty as well as their land and to prevent further

debate about tribal sovereignty (Hirsh, 2014). This came to a head after the Civil War when the

notion of consolidated nationhood left no room for tribal sovereignty. Moreover, many political

actors felt that the treaty system provided too many benefits to the tribes and prevented the

incorporation of the “vanishing race” into the U.S. society as a whole – as the Stevens treaties

had initially been intended to do (Hirsch, 2014).

The presence of unintended benefits offered by treaties is evident in the U.S.’s use of the

law to prevent further treaties with natives. In 1871, twelve years after it ratified the last of

Stevens’ treaties, Congress passed the 1871 Indian Appropriations Act. The act, Artifact Four,

prohibited the U.S. from recognizing any group within U.S. territory as “an independent nation,

tribe, or power with whom the United States may contract by treaty.” (Indian Appropriations

Act, 1871). This law effectively dispossessed any tribe that had not yet entered a treaty of their

sovereignty (in the eyes of U.S. law), further stripping them of identity, rights, and protection.
Without exception, the act dispossessed all natives of their sovereignty and rendered them wards

of the state. Congress did so without informing or consulting tribes. Even so, as they so often

did, drafters of the settler colonial facilitating law attempted to appease their morality, with an

additional line arguing that “no obligation of any treaty lawfully made and ratified with any such

Indian nation or tribe prior to March 3, 1871, shall be hereby invalidated or impaired”

consequently temporarily strengthening existing treaty protection’s standing under the scope of

the letter of U.S. law (Indian Appropriations Act, 1871).

Artifact Five: United States v. Taylor.

Early judicial victories in federal U.S. courts showcase the unintended potential of legal

guarantees to overlooked treaty rights, like fish, as a mechanism for indigenous communities to

fight against their continued dispossession and erasure. Shortly after the signing of Stevens’

treaty and the passage of additional legal protections offered by the 1871 Indian Appropriations

Act, the Washington state government began to violate the treaty's terms (Davis, 2022). The

Stevens’ treaties – all near copies of each other – resulted in the Tribes signing away their rights

to almost everything except fish and game. The treaty of Medicine Creek (Artifact 1), signed by

the Nisqually, clearly outlined that “the right of taking fish, at all usual and accustomed grounds

and stations, is further secured to said Indians in common with all citizens of the Territory”

(Kappler, 1904, 661). This right was infringed upon within thirty years of its signing (Davis,

2022) (Dougherty, 2020). New Washington residents fenced off previously native-held lands

– obstructing them from accessing fish. Tribes took legal action. In 1887, predating the founding

of Washington State, the Yakima tribe alleged that by building fences, plaintiffs had blocked

them from fishing on customary, off-reservation grounds and thus violated the Treaty of

Medicine Creek. In the United States v. Taylor (Artifact 5), the supreme court of the territory of
Washington ruled in their favor, noting that the obstruction built violated the treaty, and thus

asserted “equity will interfere by injunction and cause the removal of the obstruction” (United

States v. Taylor, 1887). This case provided a momentary victory for the Yakima and other tribes

and demonstrated the potential of treaty law as a valuable tool for protecting Native interests.

However, the same legal processes that the Yakima used to defend their fishing rights were

simultaneously being used to enable the removal of the protections offered to tribes by treaties.

Artifact Six: Lone Wolf v. Hitchcock.

The American judiciary further facilitated and legitimized the dispossession and removal

of indigenous persons through a series of biased and now condemned landmark federal cases,

which further eroded the sovereignty and legal standing of tribes and culminated in the

delegitimization of treaties. Increasingly aware of their legal obligations to indigenous peoples,

their hindrance to the westward expansion of America, and the forced assimilation and cultural

erasure of tribes, the Federal Government took legal actions to strip back or reduce the treaty

rights of tribal nations (Crepelle, 2021). With few exceptions, Tribes took to the courts to fight

these actions. Tribes achieved early victories that protected their sovereignty and treaty rights in

Cherokee Nation Vs. Georgia (1831), Worchester V. Georgia (1832) and Ex Parte Crow Dog

(1883) but saw a significant defeat in United States v. Kagama (1886) when the Supreme Court

found that Congress could regulate Tribes simply because “the Indians are within the

geographical limits of the United States” (Wiseman, n.d.). Buoyed by this ruling, in early 1892,

Congress attempted to alter the language and terms of a treaty with the Kiowa, Apache, and

Comanche tribes to reduce the lands given to the tribes (Lone Wolf v. Hitchcock, 1903). The

tribes filed a case in the Supreme Court of the District of Columbia, alleging that Congress'

changes violated the 1867 treaty they had signed, which had previously been protected as
unbreakable by the Indian Appropriations Act. Had courts followed the letter of the law, or

earlier precedents set in Cherokee Nation Vs. Georgia (1831), Worchester V. Georgia (1832) and

Ex Parte Crow Dog (1883) would have sided with the tribes (Crepelle, 2021). Instead, the court

unanimously ruled that “Congress… had the power to abrogate the provisions of an Indian

treaty” (Lone Wolf v. Hitchcock, 1903). Simply put, the federal government could break treaties

when needed or desired. The ruling, Lone Wolf v. Hitchcock, now widely panned and condemned

by legal scholars, as flagrantly racist and built around “grossly erroneous stereotypes about

Indians” is often compared to Dred Scott V. Sandford due both to its innate racism, lack of legal

strength, and catastrophic impacts (Crepelle, 2021). Like Dred Scott V. Sandford, it provides an

example of the judiciary system facilitating settler colonialism. Treaties legitimized and required

the dispossession, containment, and removal of tribes from their lands but granted Tribes some

protections. By allowing the treaties to be invalidated in Lone Wolf V. Hitchcock– after most

tribes had been removed and contained – the judiciary system manufactured common law that

enabled the federal government to dispossess tribes of the few rights the treaties had granted

them without returning the land or identities they had “traded” for these rights. With the absence

of land, sovereignty, and now their legal protections, it became more accessible for the

government to facilitate settler colonial practices and harder for tribes to resist them. Crucially,

however, the courts left one line of defense open to the treaty signatories: states had no legal

standing to violate treaties between Tribes and the Federal Government.

Artifact Seven: Photos of Two Protests

Confident that the judiciary, federal government, and public opinion would support them,

in the wake of Lone Wolf V. Hitchcock and facing growing competition for resources with Native

Tribes, many states and private actors within them, including Washington, began once again to
blatantly and openly violate their treaty obligations (Crepelle, 2021), (Aker, 2014). In

Washington, most of these violations involved fishing rights (Dougherty, 2020). While a legal

victory for tribes, Taylor did not stop fishing rights violations from occurring. The state allowed

canneries to operate in legally protected waters, passed laws restricting the rights of Indigenous

people to fish, and increased the number of commercial fishing permits and catch limits to such a

degree that tribes struggled to harvest traditional amounts of fish (Davis, 2021). Over the 75

years following Taylor, tribes continued to fight against the state in court but saw limited legal

success and a lack of federal or state government willingness to enforce any legal victories

(Dougherty, 2020). This legal ambiguity was compounded by new laws, like the Indian

Citizenship Act of 1924, which theoretically changed the legal relationship between the U.S.,

states, and tribal members and provided an additional argument for lawyers and judges to make

against tribal sovereignty (Dougherty, 2020). The ambiguous status of tribal sovereignty in the

wake of the Indian Citizenship Act of 1924, coupled with the confused mess of unenforced court

decisions, resulted in tribal leaders shifting much of their resistance efforts away from legal

efforts and towards public protest, advocacy, and fish-ins1 (Dougherty, 2020)

The failure of the most prominent public protests to shift state fishing policies or directly

cause federal intervention to enforce Pacific Northwest tribal treaties demonstrates the

unfortunate necessity and loneliness of Legal mechanisms as an effective form of resistance to

colonial dispossession. As a consequence of a series of conflicting legal decisions in state and

federal courts in the 1940s and 1950s – the majority of which saw justices and lawyers for the

state and federal government find legal loopholes to avoid treaty responsibilities – the Survival

of the American Indian Society (SAIA), worked to arrange public protests, in the late 1960’s

1
A type of protest which saw tribal members fish in and block off areas they felt were within their treaty rights to fish, but which the state did not
(Dougherty, 2020).
designed to draw attention to treaty promised fishing rights violations (Davis, 2020). Artifact

Seven presents images of the two most publicized protests supporting the Washington tribe’s

fishing rights. The first, a celebrity-backed protest, saw Marlon Brando fly to Washington state

to engage with the tribes to protest state actions2 (Dougherty, 2020). The second saw tribal

activist Billy Frank Junior – of the Nisqually tribe – lead a 1971 fish-in, which ultimately turned

violent, when “Natives, Tacoma police, and state game officials fought with guns, knives, tear

gas, and clubs” (Dougherty, 2020). While they generated publicity, the protests were

unsuccessful. As evident by its violence and limited public backlash or policy changes after the

fact, the state was unfazed. Other demonstrations were similarly unsuccessful. Their failures

demonstrate the limited options available to tribes and the unfortunate necessity of legal action to

protect the tribe’s treaty rights and resist further cultural and economic dispossession. Even so,

the protests had some impact, as they renewed federal government interest in the treaty rights of

Washington Tribes and forced attorneys for the U.S. government – now facing shifting political

pressures in support of native rights across the country – to draft a legal complaint, United States

v. State of Washington, defending the rights of the tribe against the state.

Artifact Eight: The Boldt Decision

The 1974 Boldt Decision issued in United States v. State of Washington demonstrates the

importance of treaty law to the resistance of dispossession. United States v. State of Washington

was, itself, unremarkable. It addressed the same complaints Billy Frank Junior and his peers had

been protesting for nearly a decade, and tribal entities and their supporters litigating with the

state since the signing of Stevens’ treaties. The attorney for the U.S., Stan Pitkin, U.S. Attorney

for Western Washington, argued that the state was violating the treaties signed between the

2
Brando was arrested during these protests, but was quickly released by state officials, so as to not draw further national attention to the protests
(Dougherty, 2020).
federal government and the tribes – federal law and legal precedent maintained only the federal

government could regulate tribal action or violate tribal treaties (Dougherty, 2020). The state

argued that under the equal protection clause of the 14th Amendment, Native Americans had no

special right to fish off-reservation (Dougherty, 2020).3 Presiding Justice Boldt overwhelmingly

sided with the tribes, ruling:

Because the right of each treaty tribe to take anadromous fish arises from a treaty with the

United States, that right is reserved and protected under the supreme law of the land, does

not depend on state law, is distinct from rights or privileges held by others, and may not

be qualified by any action of the state (Boldt, 1974).

Simply put, Boldt’s ruling reinforced the legal status of tribal treaty rights to fish above state

laws and codified it as common law, making it impossible for the state to legally justify any of

its current fishing practices or laws. In addition, Boldt issued a set of instructions for how fishing

rights were to be divided and managed, removing the possibility for future efforts by the state to

find legal loopholes in the treaty obligations (Boldt, 1974). Moreover, the strong wording of the

ruling provided a legal precedent that proved resilient to a slew of planned legal attacks by

Washington state officials and fishermen and made a legal reversal of course improbable (Davis,

2022). The impact of the Boldt Decision as precedent is shown in Washington v. Washington

State Commercial Passenger Fishing Vessel Ass'n, (1979) (Artifact Seven B), where a

conservative U.S. Supreme Court heavily relied on Boldt to further protect and expand the

fishing rights of Tribes in Washington state (Stevens, 1979). While federal enforcement was

required to get the state to comply with the Boldt Decision, since Washington first began

following it, the sweeping legal victory has protected the fishing rights outlined in the treaty of

3
This is itself an example of settler colonialism as the state is using legislation designed to combat racism and inequality, and the legacy of other
settler colonial actions to justify the dispossession of treaty rights.
Medicine Creek. Thus, the Boldt Decision illustrates the potential of legal proceedings to assist

tribal efforts to resist dispossession. Unfortunately, the Boldt Decision also demonstrates the

limits and downsides of law as a mechanism to resist settler colonialism.

Artifact Nine: The Trail of Broken Treaties Position Paper

While beneficial to the fight against dispossession, indigenous persons have limited

agency in the legal process surrounding treaty law and the enforcement of legal victories,

rendering them dependent upon the United States Government. The impact of the Boldt Decision

stemmed not from the strength of the arguments against the State of Washington, but from the

wording of the opinion issued by a U.S. district judge the tribes had no part in appointing

(Dougherty, 2020). This phenomenon is true of most judicial victories concerning treaty law. It

is problematic, as it places the rights of tribes in the hands of justices, who are unlikely to be

connected to the tribes, and removes the power to affect change from the tribes. Similarly, the

state complied with the legal victories entrenched in the Boldt Decision only after the federal

government threatened the state, as the tribes could not enforce the treaty themselves

(Dougherty, 2020). Simply put, despite laws and treaties establishing the tribes as independent

from the state, they lack the recourse or political power to enforce the following treaties

themselves. Moreover, to engage in the legal process, they must further acknowledge the

dispossession of their sovereignty by making themselves answerable to and reliant upon U.S.

law. In effect, participation in the most effective method of settler colonial resistance (utilization

of the judiciary branch) requires tribes to engage with and render themselves reliant wards of the

very legal system the colonists used to legitimize earlier dispossession. Across the country,

indigenous persons and legal scholars have recognized these issues and called for a change to the
existing system of judiciary-driven treaty enforcement. The most prominent of these calls for

change was the Trail of Broken Treaties Position Paper (National Parks Service, 2020).

The demands of the Trail of Broken Treaties Position Paper (Artifact Nine) highlight the

flaws with the existing regime of Indian law and the continued importance of law as a tool for

colonial resistance. The Trail of Broken Treaties Position Paper was produced in 1972 by

activists of the American Indian Movement (AIM) as they planned, announced, and executed a

nationwide march, which culminated in the occupation of the Bureau of Indian Affairs, spanning

from the west coast to DC to address the injustices faced by American Indians in the U.S.

(National Parks Service, 2020). Intended to be given to then-President Richard Nixon, the

position paper highlighted the failures of the U.S. to ratify all treaties signed by tribes, to enforce

protections currently entrenched in treaties, and of the judiciary to recognize their right to

interpret treaty law (AIM, 1972). AIM posited that the U.S.’s intentional bastardization and

violation of standard treaty practices caused these issues within the current legal regime (AIM,

1972) (Akers, 2014). As such, AIM called for a reversal of the 1871 Indian Appropriations Act

and for a return to the use of treaties to govern the relationship between “all Indian people in the

United States” and the Federal Government (AIM, 1972). AIM’s emphasis on the renewal of

treaties as a mechanism for Indian relations demonstrates the continued importance of legal

rhetoric and processes to the resistance of settler colonialism. Indeed, AIM is not unique to this

legalistic focus; the 2007 U.N. UN Declaration on the Rights of Indigenous Peoples was

influenced by AIM’s position paper and retained much of the legal emphasis on treaties

(National Parks Service, 2020). This emphasis suggests that for better or worse, law, once and

always a tool employed to facilitate the settler colonial process, has been adopted and adapted to

combat the very same process.

 Conclusion

A review of foundational legal texts and decisions impacting American Indians

demonstrates the clashing applications of law in the US by the colonizer and the colonized and

reveals a cyclical pattern of the colonized using overlooked elements of oppressive legal systems

to resist dispossession and the settler colonist altering the legal system in response. Through the

use of treaties, like Artifact One, Governor Stevens and the US government self-legitimized the

dispossession of the sovereignty and land of tribes like the Nisqually and legally enabled their

containment, removal, and erasure – as shown in Artifacts Two and Three. When tribes across

the nation perceived the treaties as an indication of self-governing ability and used their federal

recognition to fight against continued efforts of dispossession and assimilation, the U.S. used

Artifact Four – the 1871 Indian Appropriations Act to ensure that no more treaties were formed,

communicate that the federal government did not believe tribe sovereignty, and extend their legal

influence over all indigenous persons. When tribes fought back and used existing treaties

alongside the American legal system to fight against settler expansionism (as in Artifact Five, the

United States V. Taylor), the United States judicial system responded with a biased Lone Wolf v.

Hitchcock ruling (Artifact 6), which gave the federal government the ability to break the treaties

the tribes were using to defend against erasure. Finally, after Washington state continued

violating their treaty responsibilities and protests failed to generate change at the state level (as

shown in Artifact 7), Washington tribes used public pressure to force the federal government to

represent them legally and received a sweeping, legal landmark victory (Artifact 8).

While the law has been a historically effective mechanism for advancing and resisting the

settler colonial process, its relative worth and continued usage by either side merits further

consideration. As showcased by the Trail of Broken Treaties Position Paper (Artifact 9), many
indigenous activists consider the current Indian law regime a flawed but valuable tool in the fight

against the settler colonial process. Likewise, as the continued series of cases challenging United

States v. Washington and other precedents confirming treaty rights showcase, there are some

who intentionally or unintentionally seek to employ the law in a manner that facilitates settler

colonial processes (Davis, 2022). As the return to treaty negotiations proposed by AIM is

unlikely – and currently illegal – it seems likely that the courts will remain the primary agent in

the application of Indian law. This is problematic, as it further reduces the agency of tribes over

their rights and places them in the hands of individuals like the members of the U.S. Supreme

Court. In class discussions, we frequently mentioned Audrey Lord’s piece “The Masters' Tools

Will Never Dismantle the Master’s House.” Troublingly, it seems that law, the central tool of the

colonists, remains the tool best equipped to drive change. Is this, as Lord suggests, those

attempting to push for change “still define the master’s house as their only source of support,” or

is it because the master (colonist) has made it so their house is the only possible source of

support (Lorde, 2018)? Considering the history of Indian and treaty law in the U.S. and

witnessing the surprised praise heaped upon Justices like Neil Gorsuch and Boldt (decades

earlier), I cannot help but worry that the colonists have made it so that both that their house is the

only possible source of support, and that they must be involved in the dismantling of it.
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