The Oglala Lakota College has assembled an archive of oral history recordings called “A Song From Sacred Mountain Collection.” This is an excellent resource that includes digitized interviews with Cheyenne and Lakota leaders from the 1980s that were collected by the Oglala Lakota Legal Rights Fund in connection with sacred site litigation related to Bear Butte in Crow v. Gullet, 706 F.2d 856 (8th Cir. 1983). The collection provides a rare body of extensive online recorded interviews that relate to the intersection of land, sacred sites, history, and litigation.
Interlochen Public Radio’s Points North just won a national Edward R. Murrow Award for its episode on Albert “Big Abe” LeBlanc, the Bay Mills fisherman whose challenge to Michigan’s fishing restrictions led to the vindication of Great Lakes treaty fishing rights. The episode was produced by Ellie Katz and edited by Morgan Springer.
The episode describes how LeBlanc deliberately called the DNR before setting his net in 1971, challenged the subsequent prosecution, and took the case to the Michigan Supreme Court. The podcast includes his children, Bay Mills President Whitney Gravelle, and longtime Tribal attorney Candy Tierney.
Big Abe LeBlanc in front of the truck he used to deliver fresh fish to customers. (Photo shared by Whitney Gravelle)
Three Tribal Nations (Pueblo of Isleta, Prairie Band Potawatomi Nation, and Cheyenne Arapaho Tribes) along with Native students amended challenges against the United States Department of the Interior, the Bureau of Indian Education, and the United States Department of Education for unlawfully failing to consult with Tribal Nations on two sets of key agency actions directly impacting the education of Native American students.
On August 28, 2026, the Turtle Mountain Band of Chippewa Indians, the Spirit Lake Tribe, and individual Native American plaintiffs in North Dakota moved for leave to file an amended complaint in the U.S. District Court for the District of North Dakota in Turtle Mountain Band of Chippewa Indians v. Howe. This filing follows a May 2026 U.S. Supreme Court decision sending the case back to the lower courts for reconsideration under a new legal standard.
Highly recommended. Any work, especially great work like this, that connects Indigenous philosophies to federal Indian law is valuable work.
Here is the abstract:
It is time for federal submerged lands law to face a day of reckoning. This reckoning is necessary because assumed state sovereignty of submerged lands lacks a legal basis in basic property law, the Constitution, the federal trust relationship, and Indigenous law. Instead, it stems from antiquated rulings formulated, in Justice Gorsuch’s words, within the “atmosphere” of colonialism. In many instances, the historical record reflects that Tribes had neither ceded aboriginal title to such beds when a particular state was created, nor had Congress clearly abolished such title, as the law requires.
Reckoning is a strong word, but so is the authority and opportunity that comes with sovereign bed ownership. For many tribes, their creation stories, ceremonies, food sources, economies, environmental health, and cultural touchstones center upon specific waters believed to be included within their homelands, hunting and fishing grounds, and gathering places. But reckoning is not the end of the story. In the spirit of reconciliation, this article provides a reassessment of Indigenous title to submerged lands and argues that these lands are spaces of common governance in which the three sovereigns—federal, tribal, and state—share authority to manage a vital resource on which all peoples depend.
Part I begins with a discussion of why submerged lands ownership is fundamental to tribal culture and sovereignty. Part II then confront the atmosphere of colonialism that has excluded tribes from water spaces. We summarize the flawed legal test from United States v. Holt State Bank—the case most often used to determine Indian title to the submerged lands of navigable waterways—and explain why the test is both unlawful and inadequate to fulfill the United States’ trust obligations to tribes. In Part III, we propose a reckoning—a legal test better aligning with the Court’s newer jurisprudence in cases like Minnesota v. Mille Lacs Bandof Chippewa Indians and Herrera v. Wyoming. Ultimately, we advocate for the joint sovereign enterprise of placekeeping—caretaking the cultural, historical, ecological, economic, and social well-being of these spaces that serve as lifeways for us all. Through a corrected legal test to submerged lands, we will begin rebuilding the waterway “bundle” as an integrated legal whole.
Public Law 959, known as the Indian Relocation Act of 1956, was enacted on August 3, 1956. The National Archives has assembled an excellent online guide to BIA urban relocation records, including the original statute, federal relocation promotional materials, field office records, case files, and records from the relocation offices including the Chicago relocation office for folks interested in Great Lakes relocation history.
Recent reports indicate that the National Archives and Records Administration (NARA) is moving forward with plans to close several regional archives facilities, including the Chicago Regional Archives and Federal Records Center, the San Francisco (San Bruno) Regional Archives and Federal Records Center, and the Seattle Federal Records Center. Although these closures are underway, little public information has been released about what’s happening.
Last week, three of the nation’s leading archival organizations — the Society of American Archivists (SAA), the Council of State Archivists (CoSA), and the National Association of Government Archives and Records Administrators (NAGARA) — issued a joint statement expressing alarm about both the closures and the lack of transparency surrounding them. They note that, while NARA has legitimate fiscal pressures and has appropriately transitioned toward electronic records management, permanent archival collections remain physically housed at these facilities and continue to be heavily used by researchers, governments, veterans, students, historians, and the public. The organizations specifically emphasize that NARA has yet to explain how access to these permanent records will be maintained or whether affected stakeholders and Tribal Nations have been consulted.
For all Tribes, these closures would cause serious harms.
Regional NARA facilities contain the documentary record of the federal government’s relationship with Tribal Nations. Depending on the region, these collections include BIA records, treaty implementation files, agency and superintendent correspondence, allotment and probate records, census rolls, Indian boarding school records, land and trust property records, litigation files, maps, photographs, and countless other records documenting the federal trust relationship.
For the Great Lakes, the Chicago Regional Archives are especially significant. Chicago’s NARA facility includes records from Michigan, Wisconsin, Minnesota, Indiana, Illinois, and Ohio. Tribes regularly consult these collections to reconstruct treaty history, document reservation boundaries, establish citizenship and ancestry, conduct repatriation research, investigate boarding school histories, support litigation, and preserve tribal history. While NARA has digitized a fraction of these records, substantial portions of these collections remain accessible only through in-person research. A recent statement of the Chicago Area Archivists on the impact of closing NARA Chicago is here.
If these collections are relocated to more distant facilities, the practical consequences would be dire. Increased travel costs, reduced accessibility, and longer wait times would all create barriers for everyone seeking access to records documenting their communities.
In addition, we have little information about where permanent archival collections will ultimately reside, how public access will be preserved, or whether Tribal consultation has occurred. The joint statement issued by SAA, CoSA, and NAGARA specifically calls for consultation with Tribal Nations located near the records held in Chicago and San Francisco because of their unique governmental, cultural, and historical interests.
There’s also an important recent precedent from 2020 and 2021:
In January 2020, OMB announced plans to sell the Seattle National Archives facility. That proposal prompted strong opposition from Tribal Nations, states, historians, archivists, researchers, and members of Congress. Litigation followed, resulting in a preliminary injunction blocking the sale of the facility. Subsequently, the OMB withdrew approval of the closure in 2021, explaining that the process had failed to comply with the Biden Administration’s Tribal consultation policy. OMB concluded that any future effort affecting the facility would have to be preceded by meaningful Tribal consultation and a new administrative process supported by an adequate factual record.
The pleadings, briefing, and other documents from that litigation remain available on Turtle Talk.
At this stage, it’s unclear what opportunities will exist for consultation or public input regarding the Chicago, San Francisco, and Seattle facilities. These archives contain irreplaceable records documenting the histories, governments, lands, and legal relationships of Tribal Nations throughout the United States. Decisions about their future shouldn’t occur without transparency or meaningful consultation with the governments whose histories they preserve.
If anyone is aware of additional information regarding NARA’s plans, Tribal consultation efforts, or responses by Tribal governments or organizations, let us know. We’ll share updates as we learn about them.
Visitors to Chicago NARA are greeted by this statue on Pulaski Road 1.5 miles from the archives. Statue wears eyeglasses and used to hold a sign that said “Eye Can See Now.”
This comes just weeks after the Tenth Circuit reversed the District of Utah’s dismissal of the lawsuits seeking to dismantle the Bears Ears and Grand Staircase-Escalante National Monuments. The Tenth Circuit’s decision remanded the matter back to the District Court for further proceedings. Here is the briefing from the Tenth Circuit.
This Article examines the Supreme Court’s use of history and tradition in federal Indian law. In recent years, the Court has increasingly relied on Founding-era practices and historical traditions to determine constitutional meaning in areas such as firearm regulation, substantive due process, and religious liberty. At the same time, while the Founding-era record contains substantial evidence that Native nations were understood and treated as independent, sovereign political communities, this evidence has not yet been fully incorporated into the Supreme Court’s Indian law jurisprudence. Examining decisions from Oliphant to Castro-Huerta, this Article describes the Court’s approaches to historical analysis in Indian law cases and identifies areas where deeper engagement with the historical record could inform the doctrine. By centering Indian law within the broader history-and-tradition framework, this Article argues that more consistent applications of history support the robust conception of tribal sovereignty contemplated at the Founding.
Buffalo Bill and Herman Melville flashing west coast gang signs— Ray Martin Abeyta
Turtle Talk 
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