Alida Pitcher-Murray is a graduate of Northeastern University School of Law, where she dedicated her academic career to Indigenous justice and housing law. Alida is an incoming law clerk with the Massachusetts Land Court. This Article benefitted substantially from guidance and feedback received from Professor Margaret Burnham, Director of Reparations and Restorative Justice Initiatives and the Civil Rights and Restorative Justice Project at Northeastern University School of Law, and Professors Stefanie Leahy and Nicole Friederichs at Suffolk University Law School. The author is a non-Native scholar of Indian law. She does not represent or speak for any Tribe or Indigenous community.

This Article uses the terms “Indigenous” and “Native” to refer to the Indigenous people of the United States, but “Indian country” to refer to Indigenous land. These terms are used regularly by scholars and activists. The Article uses the term “Indian” only when quoting other sources. This is a legal term of art used in legal decisions, federal statutes, and treaties. See, e.g., Johnson v. McIntosh, 21 U.S. (8 Wheat) 543 (1823); 18 U.S.C. §1151 (2012); Treaty of Fort Laramie, 15 Stat. 649. However, Indigenous-led organizations, such as Indigenous Network, characterize the term “Indian” as a “colonizer word.” Judith LeBlanc, Change the Offensive Name -- Sign Petition Here!, Indigenous Network (Jan. 27, 2023), https://www.indigenousnetwork.org/post/change-the-offensive-name-sign-petition-here. In addition, for the purposes of this Article, I refer predominantly to the experiences of Indigenous communities in the lower 48 states. Native Alaskan and Hawaiian communities have experienced parallel, but distinct, subjugation by the federal government. It is beyond the scope of this Article to examine these distinctions.