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§3.2 NATIVE AMERICANS
Building on models already tested by the Spanish, the French, and the British,America advanced its takeover of the lands held by Native Americans
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through resort totreaties — easily made and as easily abandoned — open warfare waged with, first,superior weapons and, later, with overwhelming numbers, and, ultimately, throughgenocide.
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Writing in the mid-1830s, Alexis de Tocqueville contrasted the outright policies of the Spanish, who tracked and exterminated the Indians as they would wild beasts, with those of the Americans, who accomplished the same end “with singular felicity, tranquilly; legally, philanthropically, without shedding blood, and withoutviolating a single great principle of morality in the eyes of the world. It is impossible todestroy men with more respect for the laws of humanity.”
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De Tocqueville’s observationis obviously tongue-in-cheek, because there was, in fact, great bloodshed and greatsavagery directed at those deemed to be savages. His description does encompass howthe law was manipulated to justify whatever was necessary to get rid of the Indians, who
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There is much discussion about what term should be used to refer to Native American peoples. Many people, including people who are themselves Native American, choose to use the term “Indian” or “American Indian” and see such use as a reclamation of an oppressive colonial nomenclature. Others prefer “Native American” or “First American.” This author, as a non-Native American, has chosen to use the term“Native American” as it reflects the fact that Native peoples are indigenous to America and moves awayfrom the often stereotypical term “Indian.” When other scholars or sources are cited, the terms they use arenot altered, which accounts for the variation throughout the chapter.
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The traditional myths about the winning of the West have been deromanticized. The virtual eradication of the Western Indian is painfully detailed, for example, in Dee Brown, Bury My Heart at Wounded Knee(1970). Indian politics is surveyed with insight, wit, and militancy in Vine Deloria, Custer Died for Your Sins (1969).
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Cited in Rennard Strickland, Genocide-At-Law: An Historic and Contemporary View of the NativeAmerican Experience, 34 U. Kans. L. Rev. 713, 718 (1985-1986). A more recent commentator observed:“[H]eavy reliance on law is characteristic of many colonial societies that are typified by . . . extremeimbalances of power. The use of law by colonizers to execute and rationalize oppressive policies, notablythe acquisition of native lands for European settlement, is poorly explained as an effort to gain the consentof thoroughly dominated indigenous populations. Rather, . . . the use of law under such circumstancesreflects the needs of dominant colonial groups to maintain internal cohesion and morale, and, to a lesser extent, to gain international approval for their policies.” George E. Bisharat, Land, Law, and Legitimacy inIsrael and the Occupied Territories, 43 Am. U. L.Rev. 467, 470-471 (1994).
 
refused to depart from what whites felt were lands that were part of the “manifestdestiny” of this nation. Indeed, American Indian law developed with and was closely tiedto the means by which whites displaced Indians. The Court adopted a number of policiesthat to the observant were hardly more than rationalizations for that displacement. As onearticle put it, a cynic would not be far off the mark who defined Indian law asbased onthe separative premise when it was possible to move the Indians to other territory and onthe assimilative premise when land scarcity required that the Indian and his lands be brought into the totally alien private-property system of the white man, where the Indiancould easily be dispossessed by such devices as inflated tax appraisals and long-termleases returning minimal rents.
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Comedian Dick Gregory, fresh from a lengthy lecture on how American law dealtwith Native Americans, went outside and said, “Hey, look at that beautiful Cadillac car. Ithink I will discover it.”
§3.2.1 Federal Power over Indians: Its Sources, Scope, and Limitations
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The mystique of plenary power has pervaded federal regulation of Indian affairs fromthe beginning. While the Articles of Confederation contained a general power over Indianaffairs, the Constitution enumerates only one power specific to these affairs: the power “[t]o regulate Commerce . . . with the Indian tribes.”
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The Plenary Power Doctrine, a
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Red, White, and Grey: Equal Protection and the American Indian, 21 Stan. L. Rev. 1236, 1238-1240(1969). Chief Joseph, one of the last great Indian leaders observed, “The white men made us many promises. They only kept one. They said they would take our land and they took it.”
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Nell Jessup Newton, Federal Power over Indians: Its Sources, Scope, and Limitations, 132 U.Pa. L. Rev.195 (1984). In a lengthy article, a major portion of which is excerpted here with her permission, Universityof Denver Law School Dean Newton traces the judicial “flexibility” that categorized American Indian law.Footnotes, where included, are renumbered to conform with those in this chapter.
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U.S. Const. art. I, §8, cl. 3.
 
fixture of American Indian law since John Marshall provided its first justification in1832,
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can be traced not only to this commerce power but also to the treaty, war, andother foreign affairs powers,
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as well as to the property power.
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Each has beencharacterized, historically, as vesting Congress (or the President) with almost unlimited power in contexts not involving Indians.
 A. The Treaty Era: Foreign Affairs and Indian Commerce (1776-1871)
The absence from the Constitution of a general power over Indian affairs is notsurprising to students of history, for at the time the Constitution was drafted, the Framersregarded Indian tribes as sovereign nations, albeit nations that would soon either movewest, assimilate, or become extinct. Thus, the same powers that sufficed to give thefederal government a free rein in the international arena were viewedas sufficient toenable the new government to deal adequately with the Indian tribes. In formulatingfederal policy toward Indian tribes in the early years of the Constitution, PresidentWashington and Secretary of War Knox followed the policy promulgated by the BritishCrown — though not always followed by individual colonies — of dealing with Indiantribes as sovereign nations. Their principal reason was practical: Earlier attempts byindividual colonies and some states under the Articles of Confederation to assert power over Indian tribes, especially the power to seize tribal lands, had caused conflicts.According to one historian, “[T]he country, precariously perched among the sovereignnations of the world, could not stand the expense and strain of a long drawn-out Indian
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Worcester v. Georgia, 31 U.S. (6 Pet.) 515, 557-562 (1832).
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U.S. Const. art. II, §2 (treaty); id. art. I, §8, cls. 11-16 (congressional war powers).
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U.S. Const. art. IV, §3 (property clause).
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