President Andrew Jackson’s Native American Policies

Andrew Jackson was the seventh president of the United States, in office from 1829 to 1837. Many important events happened during his presidency, and here Richard Bluttal looks at Jackson’s policies towards Native Americans.

An 1820s portrait of Andrew Jackson, By Thomas Sully.

Early years of Westward Expansion

To understand the basic elements of the Indian Removal Act 1830, we need to first understand the status of the United States at this critical juncture in time. In the early 19th century, American settlers were moving toward the frontier at an alarming rate. As the coastal regions were beginning to crowd, southern and western lands were in high demand. This prompted pioneers to begin settling deeper into Native American territory.

White Americans, particularly those who lived on the western frontier, often feared and resented the Native Americans they encountered: To them, Native Americans seemed to be an unfamiliar, alien people who occupied land that white settlers wanted and believed they deserved.

Some officials in the early years of the American republic, such as President George Washington, believed that the best way to solve this “Indian problem” was to simply “civilize” the Native Americans. The goal of this civilization campaign was to make Native Americans as much like white Americans as possible by encouraging them convert to Christianity, learn to speak and read English and adopt European-style economic practices such as the individual ownership of land and other property (including, in some instances in the South, enslaved persons).

Andrew Jackson was the seventh president of the United States. Before that, he was a successful general in the War of 1812 and made many contributions to the country as a lawyer, judge, statesman, and war hero. Despite his illustrious career, Jackson remains one of the most controversial figures in American history over one issue alone—the Indian Removal Act of 1830. This monumental law would affect history like no other. It was developed for the purpose of moving Native American tribes from east of the Mississippi River to lands in the west.

Lately, Historians have been asking, why did Andrew Jackson have an extreme hatred for Native Americans, or it was all fictional. In 1813, Andrew Jackson sent home to Tennessee a Native American child who was found on the battlefield with his dead mother. This boy, Lyncoya, (1811-1828), may have originally been intended as merely a companion for Andrew Jr., but Jackson soon took a strong interest in him. Lyncoya was educated along with Andrew Jr., and Jackson had aspirations of sending him to West Point, as well. 

What Tennessee in its frontier days did not offer was an easy life. The people who came to Tennessee did not travel with a wealth of possessions. They possessed little and knew how to manage with what they had. To eat, they had to grow their food or hunt it. They had come to conquer the land, but Tennessee did not readily surrender to their efforts as they chopped down the trees and cleared the land for agriculture. The houses were rudimentary, with the family sharing common living space. But they had come not only for prosperity but freedom, and they were willing to work hard to raise children who would grow up in liberty.

The General

Jackson made himself available when military service called. He was brave and known early on as a bit wild so Tennessee was perfect for him. In 1802 was appointed major-general of Tennessee’s militia military service and stationed where troops were needed along the frontier

1813 he headed south, where he was victorious in battle, defeating the Native Americans at Tallushatchee and Talladega. Jackson was discovering that he had a flair for leadership and a knack for soldiering. With a force of 5,000, Jackson’s volunteers defeated the Creek warriors at Horseshoe Bend, bringing the Creek War to an end in March 1814. The United States needed a hero in the war of 1812, and Andrew Jackson was going to fit the bill very nicely.

Jackson heard that the British were planning to invade the South, he went to Mobile, Alabama to strengthen the city’s fortifications. He then, although he was not authorized to do so, invaded Florida, which belonged to Spain. His motive was to get to nullify the dangers of the tribes who were allied with Great Britain and hostile to the Americans. Jackson and his troops headed for Spanish Florida. Jackson captured Pensacola in November 1814 and then set off on the trail of the British, who were on their way to New Orleans. The Americans, consisting of a military force of regular U.S. troops, Tennessee militia volunteers, with militia from Kentucky, Louisiana and the Mississippi Territory, free blacks, Native Americans, Creoles and even a band of pirates, were outnumbered.The British invasion began on December 14. On December 23, Jackson’s forces halted the advance of the British troops, initiating two weeks of battle as the British sought a way through Jackson’s defenses to reach New Orleans. On January 8, a full- scale attack by the British was launched. Jackson’s forces were outnumbered two- to- one at the battle. They were not a cohesive fighting unit. Despite these drawbacks, on January 8, 1815, Jackson’s 5,000 soldiers defeated the mighty forces of the British at the Battle of New Orleans, forcing the expert soldiers of the British Empire to withdraw from Louisiana. New Orleans was saved, the peace treaty between the United States and Great Britain had already been signed in Belgium, but slow communication prevented Jackson from knowing that his battle victory was unnecessary. The Treaty of Ghent had brought the war to an end several weeks before Jackson’s conclusive victory, although it would not be ratified by Congress until February 16, 1815. It was not, however, unappreciated. His military prowess also did much to boost the confidence of a very young country which had no longstanding military heritage to boast of, as did its European counterparts. The world saw, through Jackson’s boldness, that his reputation was well known to the tribes, and the Creeks, Cherokees, Chickasaws, and Choctaws signed treaties which left them with significantly reduced land while the United States was able to increase its territory. What would benefit the Americans the most would be the undoing of the tribes, who would eventually be forced to leave their ancestral homes.

In 1817, Jackson returned to military leadership during the First Seminole War. In 1805 thru 1816 there was increasing friction between white settlers, Florida Native Americans and the Creek Confederation. The Seminoles began hiding runaway slaves who had escaped from southern plantations into Spanish Florida. In March of 1818 General Andrew Jackson crossed into Florida attacking the Spanish fort at St. Marks with 3, 500 men and then marched east to the Suwanne River and attacked the village of Chief Boleck. Many Native Americans escaped into the swamps. Jackson was unable to find or capture the Seminoles thus ending the First Seminole Indian War.

His success in military ventures brought more land to the growing nation, but by securing so much land, a new crop, which would thrive in the southern soil, would eventually bring both prosperity and tragedy to the region: cotton became the dominant agricultural produce in the South. It would, ultimately, expand the number of enslaved peoples, creating an irreparable division between North and South that would only be solved by war.

Jackson’s Presidency

The Indian Removal Act was passed by Congress on this day in 1830 and signed by President Andrew Jackson two days later. The act called for the removal of Native Americans residing within state borders in the East to a newly created Indian Territory in present-day Oklahoma and parts of Nebraska. The goal was to free up state lands for white settlers, particularly in the Southeast, where a growing population clamored for access to agriculturally rich land on which to grow cotton.

While some members of each affected tribe—which included the Cherokees, Choctaws, Chickasaws, Creeks, and Seminoles—left voluntarily, most refused to leave and fought back, through physical and legal means.

Jackson was much more tolerant toward the issue of state’s rights when the state of Georgia claimed millions of acres of land that, according to federal law, belonged to the Cherokee tribe. The Supreme Court ruled that Georgia had no authority over the tribal lands, but Jackson refused to enforce the ruling. The Cherokees began to try to assimilate. Moravian missionaries taught the Native Americans how Europeans lived, farmed, and worshiped. The Cherokee, along with the Creeks, Chickasaws, Seminoles, and Choctaw, became known as the Five Civilized Tribes for their efforts. The Cherokees adopted a constitutional government and developed a written language, further adopting the ways of the white man. But for Americans, and particular for Georgians, this was futile. All they knew or cared to know was that Native Americans were savages. More to the point, these savages owned land that Americans coveted. One of the foundations of Jackson’s presidency was the  goal of removing all Native Americans in the Southeast, a goal which was part of the motivation for the 1830 Indian Removal Act. The Cherokees did not meekly submit. Using the political knowledge they’d gained by studying the white man’s ways, they sent their chief, John Ross, a mixed- blood Cherokee who spoke English and learned the law, to Washington D.C. to plead their cause. But when the Congress failed to be receptive, they took their case to the Supreme Court. Chief Justice John Marshall agreed with Ross’ arguments, and the Court ruled that the federal government, not the states, held authority over the Cherokee nation. Jackson paid no attention and supported Georgia in its activities against the Cherokee.

Cherokees had three years to move west. Jackson wanted the Native American lands, but he had other goals which he pursued passionately as well. In the winter of 1831, under threat of invasion by the U.S. Army, the Choctaw became the first nation to be expelled from its land altogether. They made the journey to Indian Territory on foot (some “bound in chains and marched double file,” one historian writes), and without any food, supplies or other help from the government.

Thousands of people died along the way. It was, one Choctaw leader told an Alabama newspaper, a “trail of tears and death.”

The Native American removal process continued. In 1836, the federal government drove the Creeks from their land for the last time: 3,500 of the 15,000 Creeks who set out for Oklahoma did not survive the trip.

Jackson Returns to Tennessee

Just as Jackson seemed to exemplify the vigor and energy of the new country, he was also an innovator to the office of the presidency. He was the first president to ride a train and the second to be photographed. The White House that he left, with indoor toilets and running water that had been added during his tenure, was a more modern building than it had been when he moved in. He had done much to transform the office he had occupied, both politically and aesthetically.

Jackson’s Legacy

Jackson believed in the common man, not the elite. His presidency supported democracy as he believed it was meant to be practiced, not as the province of the rich and powerful, but as the birthright of ordinary people. It was the people Jackson held, who had the power to shape the nation. Historians may doubt the morality of his effect, but no one can contest the concrete results of his presidency. He paid off the national debt, expanded the boundaries of the nation, issued a new currency, and made America’s ties with foreign nations stronger. He was also, in an abstract way, one of the architects of the American myth. If a man proved himself willing to work hard, he could not only succeed in this new country, but he could rise to a position of power. In the nations of the Old World, where inherited land and titles dictated the path to empowerment, there was no fresh blood infusing upward mobility. Americans believed, because they had witnessed the process in men like Jackson, that a man could be born with nothing, but could profit himself by applying himself to the endless task of building his country.

Jackson was not, however, a visionary: slavery continued to be an economic factor, rather than a moral quagmire, for Jackson’s era. Native Americans lost more and more territory and sovereignty as the young country expanded at the expense of the natives who had been there first. The movements that would soon blossom in support of the abolition of slavery and the rights of women were on the horizon, but under Jackson, society was dominated by white men who wielded the power. Jackson saw nothing wrong in awarding government offices to his supporters and replaced many of these officials with his own people, beginning what would become known as the spoils system. He was, in this instance, true to his Southern beliefs, as he supported the rights of the states over the federal and judicial authorities. He used his veto power without a qualm, vetoing more bills than had all of the previous presidents combined. He opposed legislation which threatened slavery, supported the availability of cheap public lands, and refused to recognize the judgment of the Supreme Court regarding the rights of the Native American tribes.

For better or for worse, the Age of Jackson imbued the young nation with the raw ingredients it would need to reach its potential. The country believed in its power to do whatever it wanted to do; very different from the established, traditional model of nations long settled into their routines.

What do you think of Andrew Jackson’s Native American policies? Let us know below.

Now read Richard’s piece on the history of slavery in New York here.

Chief Flying Hawk – A Great Native American in Troubling Times

Flying Hawk was an important Native American as white settlers moved across the western US in the latter half of the 19thcentury. He met 10 US presidents and later became part of Buffalo Bill’s Wild West troupe. Alec Marsh explains.

Alec’s new book, Ghosts of the West, is now available here: Amazon US | Amazon UK

Chief Flying Hawk, Oglala Lakota.

He fought at Custer’s Last Stand and counted the warrior Crazy Horse as a close friend, as well as his cousin. He met ten US Presidents and ranked Teddy Roosevelt above them all. He was present at the death of Sitting Bull in 1890 and attended the massacre of Wounded Knee. He then travelled the world as a star of Buffalo Bill’s Wild West troupe.

And before dying at 77 in 1931, Chief Flying Hawk also acted as translator for the writer John Neihardt, thereby helping him to create a seminal work in Native American culture, Black Elk Speaks. More than this, Flying Hawk also produced his own history of America, finally published in 1946, ‘so that the young people would know the truth. The white man’s books about it did not tell the truth’.

So if you haven’t already, I believe it is high time you acquainted yourself with the Native American chief, Flying Hawk, a renaissance man who was a leader, an educator and warrior in equal measure. The son of Chief Black Fox of the Oglala Lakota – a leader who lived for decades with an arrow lodged in the back of his sky before dying in his eighties, Flying Hawk was born in 1854 at a time when the Sioux’s traditional way of life was still largely unaffected by white men.

The buffalo herds upon which the Sioux’s civilization depended still roamed abundantly across the great plains of the West. And when European-Americans did come, they came to trade – not to necessarily to live, or to dominate. That, however, was all about to change.

But as a result Flying Hawk grew up in a way that would have been familiar to those who had gone before him: learning the art of warfare by fighting skirmishes against rival tribes – the Crow and Piegan. He took part in his first battle aged ten, against soldiers protecting a wagon train. ‘I do not know how many we killed of the soldiers, but they killed four of us,’ he would say later. ‘After that we had a good many battles, but I did not take any scalps for a good while. I cannot tell how many I killed when a young man.’

Red Cloud’s war

More fighting was to follow. Just two years later, in 1866, armed conflict broke out between the Sioux and the US, over the latter’s decision to build forts along the Bozeman Trail, a road through the Powder River country in modern day Wyoming and Montana – land belonging to the Sioux and a prime hunting ground. What followed – known as Red Cloud’s War – was a two year guerrilla conflict in which the Native Americans, led by another Oglala Lakota chief Red Cloud, were able to outwit and outmaneuver their better-armed opponents. In December 1866, Crazy Horse, who would come to world’s attention for his part in defeating Custer at the Battle of the Little Bighorn ten years later, commanded a small party of warriors to lure out a large body of soldiers from one of the forts – leading them into a deadly ambush. The Fetterman Fight or Massacre, left 81 men under the command of Captain William J Fetterman dead and was the biggest military defeat suffered by the United States at the hands of the Plains Indians until Custer’s Last Stand in 1876. Red Cloud’s war concluded in victory for Sioux with a peace treaty signed 1868 at Fort Laramie in eastern Wyoming. It is still recognized as an international treaty in law today.

Moreover its an international treaty which the United States breached in 1876 with the invasion of the Black Hills, the Sioux’s last great hunting ground, following the discovery of gold there in 1874.

The Sioux, now led by Sitting Bull, Flying Hawk’s uncle, and Crazy Horse, fought back: and so began the Great Sioux War of 1876-77. Red Cloud, whom Flying Hawk described as ‘the Red Man’s George Washington’, had been to Washington and New York after the peace of 1868 and now knew what the Native Americans were up against. He did not join the call to arms in 1876. Flying Hawk was there every step of the way.

Custer’s last stand

The defining moment of this war was the Battle of Little Bighorn in June 1876, where Flying Hawk fought alongside Crazy Horse, the architect of the victory. In his graphic account of the battle he described how it began with the US cavalry firing on their village, and how the Native Americans quickly had the soldiers on the back foot. ‘When we got them surrounded the fight was over in one hour,’ Flying Hawk recalled. ‘There was so much dust we could not see much, but the Indians rode around and yelled the war-whoop and shot into the soldiers as fast as they could until they were all dead. One soldier was running away to the east but Crazy Horse saw him and jumped on his pony and went after him. He got him about half a mile from the place where the other soldiers were lying dead.’ 

He added: ‘It was a big fight; the soldiers got what they deserved this time. No good soldiers would shoot into the Indian’s tepee where there were women and children. These soldiers did, and we fought for our women and children. White men would do the same.’

Despite the victory the chiefs quickly realized that the game was up: Washington put the Sioux reservations under the authority of General Sherman and all Native Americans were henceforth to be treated as prisoners of war. Those that were off their reservation would be treated as hostiles. Rather than submit to this, Sitting Bull led his band to Canada; Crazy Horse was killed in a scuffle after handing himself over at Fort Robinson in Nebraska. ‘He was honored by his own people and respected by his enemies,’ said Flying Hawk. ‘Though they hunted and persecuted him, they murdered him because they could not conquer him.’ The murder of Crazy Horse proved to the harbinger of the treatment that Sitting Bull would receive 13 years later on his return from Canada.

By this point the Great Sioux Reservation had been broken into five reserves occupying perhaps half the original land promised to them, having been appropriated for white settlers by the US government. In 1890 the Ghost Dance, a religious movement swept across the hungry and cold Sioux people, prompting fears of an uprising among the authorities. Once again Flying Hawk was close to the action: his brother Kicking Bear, a holy man and chief, was a leading figure of the movement, and Flying Hawk was among the first to witness the results of the massacre at Wounded Knee, when soldiers of the Seventh Cavalry machine-gunned more than 200 mainly Sioux women and children camped in the winter snow outside the Pine Ridge reservation in South Dakota. Flying Hawk described seeing the bodies of women and children lying under a blanket of snow – and asserted that the attack was retaliation for the ‘Custer affair’ 13 years before.

Extermination of the buffalo

By now the way of life that he had grown up with was gone – including the last great herds of the buffalo, wiped out by the mid-1880s. The whites, Flying Hawk claimed, ‘could not fight them fairly and win’.

And then, having lived through all of this calamity and change, in the years that followed, Flying Hawk turned to show business. Following in the footsteps of Sitting Bull and Red Cloud, he joined Buffalo Bill’s Wild West show in 1898 and while it is said he initially chafed at being asked to perform the displays of the battles he had taken part in, he soon made peace with the life on the stage. Not only was there was money in it, but the shows celebrated performers like him; it also allowed them to communicate something of their way of life to the outside world. Flying Hawk spent the next three decades ‘Wild Westing’, as it was known, touring the US and Europe with Colonel William Cody’s show and later joining the Miller Brothers 101 Ranch show and Sells Floto circus. He finally retired from touring in 1930, the year before he died. That was also year he acted as an interpreter for the writer and ethnographer John G. Neihardt in his interviews with the Oglala medicine man Black Elk, which remains a powerful and important testimony to this day.

Flying Hawk also toured schools speaking about Native American history, which became part of his effort to tell the story of his people from the Native American perspective. This he achieved most comprehensively through a series of interviews with his friend Major Israel McCreight, becoming Firewater and Forked Tongues – A Sioux Chief Interprets US History, published in 1946 under McCreight’s name. When each age was finished, McCreight would read it to Flying Hawk who would apply his thumbprint approving the pages individually.

In a foreword to Firewater, Ohitika, or Benjamin Brave, ‘a member of the Sioux tribe’, who tells us that his grandfather fought at the Little Bighorn, says this of Flying Hawk: ‘Perhaps no other Indian of his day was better qualified to furnish reliable data covering the period of the great Sioux war, beginning with the ruthless exploitation by rum-sellers, prospectors and adventurers, of their homes and hunting grounds pledged to them forever by sacred treaty with the Government, and ending in the deplorable massacre of Wounded Knee.’ Quite possibly.

Certainly Flying Hawk was at the center of the action, and somehow lived to tell the bloody tale, which he did. He also inspired those he met and remained unequivocal about what he witnessed. ‘Nowhere in the history of mankind is there to be found a parallel,’ Flying Hawk said, ‘nothing so cruel, un-American and wholly inhuman. Cortez in Mexico and Pizarro in Peru carried on their wars of extermination in the name of religion... But the white man had no justification for this ruthless campaigns against the red race.’

The cover of Alec’s new book. Imaged provided by and included with the permission of Headline Accent.

You can read Alec’s new book, Ghosts of the West, here: Amazon US | Amazon UK

It is published by Headline Accent.

How American Colonial Law Justified the Settlement of Native American Territories

TThe nature of constitutions of Native Americans is a debated topic in American history, particularly as those constitutions played a role in the ‘legitimacy’ (or otherwise) of the settling of Native American lands. Here, Daniel Smith discusses Western colonial law, property rights, and the constitutions of Native Americans - and how the constitutions are seen to have altered with Western concepts of property rights.

You can read Daniel’s past articles on California in the US Civil War (here) and Medieval jesters (here).

Major Ridge, a leader of the Cherokee in the nineteenth century who was to play a major role in ceding Cherokee lands to European-American settlers.

The idea of independent sovereignty with full “property rights” observed is a Western concept that Native Americans adopted. The Cherokee Constitution, for example, was a purposeful effort by the Cherokee to adopt Western ideals, as through their observations they felt a sense order, structure, justice, and liberty. Hence, they moved to partition the Cherokee Nation from tribal culture, and establish a more formal and legal presence within North America. 

In Article 2, section 1, “The power of the Government shall be divided into three distinct departments---the Legislative, the Executive, and the Judicial.”[1] This is the same wording as the American Federal Constitution, in article 1, section 1. This leads me to believe that the Cherokee established their constitution under the same formatting as the Federal Government for reasons of: 1.) Tribal Security, 2.) Tribal Continuity, and 3.) Regional Relief of Tensions.

According to todayingeorgiahistory.org, “It was designed to solidify the tribe’s sovereignty and resist white encroachment and removal -- and to counter American citizens stereotyping of Indians as savages. The Cherokee constitution proved controversial with both other Cherokee, who saw it as a threat to tradition, and the state of Georgia, which thought it threatened its sovereignty over the tribe. Georgia continued, and succeeded in, its relentless pursuit of Cherokee removal, despite the Constitution adopted on July 26, 1827” [2] 

That is made worse when you learn that the Cherokee were attempting to assimilate into American society as best as they could while maintaining their own sovereign identity. Oppositely though, I find it hard to believe that there was not misconduct between Georgia and the Cherokee – on both sides. Typically, as in geopolitics, there is always a reaction to an action whether negative or positive in outcome.

I had an argument where a peer said, "A constitution that has been in practice since before the upstate settlements in the 1600s and may hold partial responsibility in the development of the settlers nation. As proof, they cite records kept by the colonists. An Onondaga named Canassatego, suggested that the colonists form a nation similar to the Iroquois Confederacy during a meeting of the Provincial Council of Pennsylvania in Lancaster on June 25, 1744.”

INFLUENCES

There is an argument that the ideals for some Native American nations, such as the Cherokee, predate any influence provided by the Europeans. Where we see the most similarity is in how these Native Americans formatted their laws to reflect that of the settlers. This may have been done in the attempt to most effectively convey their already sovereign nations to these foreigners in a way that most effectively would do so.

I would humbly disagree that "the ideals for some Native American nations, such as the Cherokee, predate any influence provided by the Europeans." There is a lack of evidence that Western-style Native American political ideals predated European Influence, especially when it comes to the Constitution of National Governments. Here is why: colonial law and property ownership is a particularly Western concept (even though all cultures understand ownership over physical items).

An example here would be the Magna Carta of 1215. The Magna Carta was a signed document and statement that embodied the principle that both sovereign nations and sovereign people are beneath the law and subject to it. Later, both Englishmen and American Colonists cited the Magna Carta as a source of their freedom. Native Americans did not have access to this document.

Even before 1215, Alfred the Great, an English King from 871-899, was a strict follower of Catholic Saint Patrick. After many Viking invasions, Alfred the Great instituted Christian reforms in many areas of life, including government. These reforms were based on the Ten Commandments as the basis of law and adopted many other patterns of government based on religious texts. My point here is that, it is very difficult, if not impossible, that Native Americans could have established a style of Western or "Christian Constitution" without direct Western European influence.

EVIDENCE EXPLAINED

According to the Michael P. Gueno, “English common law jurists expounded upon the argument for the English monarchy’s right to conquer non-Christian territories, most articulately described in Lord Chief Justice Edward Coke’s dicta in Calvin’s Case. Coke argued that all non-Christians were perpetual enemies, of the Christian and by their very nature are in a state of war with Christian nations.[3] However, despite the general consensus that Native American tribes lacked any rights to the territories that they occupied, in practice, colonists often felt compelled to obtain at least some formal semblance of legal consent from the tribes through treaties or purchase agreements to assert their claim upon tribal lands”. This shows that, despite how the settlers took the lands, there was still a desire to have a legal basis for taking the lands.

Mr. Gueno continues to state that, “Some colonists even denounced the unilateral rights and universal sovereignty of European Christians over the Native Americans. Colonial theologian Roger Williams rejected the assumption that being white and Christian were sufficient conditions to legitimize colonization or conversion. He argued that since Native Americans clearly believed that they owned the land, Native American–inhabited territories could not be legally treated as vacuum domicilium and settled without regard for tribal presence.” This helps to show that property ownership was understood. [4] 

Gueno concludes, “Europeans continued to debate conflicting religious interpretations of Indian rights during the early North American colonial era. Yet, whenever Native Americans were numerous, proximate, and potentially threatening, colonizing peoples felt pressed to seek Indian consent for new settlements. Thus, European powers ascribed, to some extent, in practice and in theory a sufficient degree of sovereignty to Native tribes to legitimately transfer claim of lands and administer their own communities.”[5]

How Native American lands were taken by Europeans, and how legal this was, is a complex issue in North American history. Interpretations are one of the major battles in presenting history, but I hope this article helps to explain more about Colonial Law and Native America.

What do you think of the arguments in the article? Let us know below.

Finally, Daniel Smith writes at complexamerica.weebly.com.

Sources

[1]"1839 Constitution." Cherokee Nation, www.cherokeeobserver.org/Issues/1839constitution.html. Accessed 26 Nov. 2018.
[2] State of Georgia. "Cherokee Constitution." Todayingeorgiahistory.org/, 2013, www.todayingeorgiahistory.org/content/cherokee-constitution. Accessed 26 Nov. 2018
[3] David H. Getches, Charles F. Wilkinson, Robert A. Williams, Jr., Matthew L. M. Fletcher, & Kristen A. Carpenter, eds., Cases and Materials On Federal Indian Law, 7th ed. (Saint Paul, MN: West Academic Publishing, 2017), 63.
[4] Henry S. Commanger, ed., Documents of American History, 9th ed. (Upper Saddle River, NJ: Prentice Hall, 1968), 5–10.
[5] Gueno, Michael P. "Native Americans, Law, and Religion in America." Oxford Research Encyclopedia of Religion, University of Wisconsin–Whitewater, 10 Nov. 2017, religion.oxfordre.com/view/10.1093/acrefore/9780199340378.001.0001/acrefore-9780199340378-e-140. Accessed 10 June 2018.