It may have gone unnoticed, but Justice Alito’s concurring opinion in Brown v. Entertainment Merchants Assn. listed a game where the “goal is to rape Native American women…” in his list of awful games offered by the video game industry. His citation for that game was a 1982 issue of People Magazine, available here (Custer Article). An old game, but it definitely is part of an ugly theme in Indian law and policy — sexual abuse of American Indian women.