Department of the Interior Timeline

  • Chris Edwards
  • 1783: The Treaty of Paris gives the United States ownership of all lands south of Canada, east of the Mississippi River, and north of Florida.1 In the 1780s and 1790s, the federal government gains further territory as the states cede to it their western land claims.2
  • 1785: Congress adopts the Land Ordinance, designed to regularize the sale of federal lands.3 For the nation's first century, the federal government's general policy is to dispose of its lands by selling them or transferring them free to settlers, veterans, railroad companies, and state governments.
  • 1787: The Northwest Ordinance incorporates the idea that western lands should be held initially by the federal government and then transferred to new state governments when they are formed.
  • 1787: The United States Constitution gives Congress the "power to dispose of and make all needful Rules and Regulations respecting the Territory and other Property belonging to the United States."
  • 1789: The first Congress under the new Constitution considers creating a separate department for internal affairs, but ultimately decides to put both domestic and foreign activities under the Department of State.
  • 1796: The Public Land Act aims to sell federal lands in the West and collect revenues to pay down the government's debt. However, this law and other pre-1862 efforts to raise revenues from federal land sales are not very successful. The government sets prices too high, and settlers generally ignore federal rules and squat on lands opening up in the West. The 1862 Homestead Act finally incorporates the reality that it is better to provide western lands to settlers for free.
  • 1803: The Louisiana Purchase adds vast land holdings to the federal government. The purchase roughly doubles the size of the nation. The United States expands further with the addition of Florida in 1819, Texas in 1845, the Oregon territory in 1846, and the Mexican Cession area in 1848. These areas put an additional 1.3 billion acres of land under federal control.4
  • 1812: The General Land Office is created to manage federal land sales in the West and to handle land bounties given for military service. It is the forerunner to the Bureau of Land Management.
  • 1824: Secretary of War John C. Calhoun establishes the Bureau of Indian Affairs within the Department of War.5 The agency is also called the Indian Office. Indian tribes are treated as foreign nations and the federal government negotiates treaties with them. The bureau is moved to the new Department of the Interior in 1849.
  • 1830: President Andrew Jackson signs into law the Indian Removal Act. The law is designed to peacefully move Indians in eastern states to west of the Mississippi River, but the federal government uses force to move noncompliant tribes.6 The government, for example, sends 7,000 troops to remove 16,000 Cherokees from their lands in Georgia in 1838. The forced march westward is known as the Trail of Tears, and it results in the deaths of 4,000 people from cold, hunger, and disease.
  • 1847: The Mormons arrive in Salt Lake Valley and within a year create an irrigation system covering 5,000 acres.7 Private irrigation efforts are pursued in many areas of the arid West, and by 1900 about 7.5 million acres of farmland in the 17 western states are irrigated.8
  • 1848: The California Gold Rush begins before Congress has any detailed mining policies in place for federal lands, but the miners quickly develop their own legal institutions. An official history of Interior notes: "Miners, who quickly spread their search for precious metals across to the Pacific Coast and Rocky Mountains, were forced to develop their own laws and regulations. Prospectors organized mining districts and devised rules as to how claims were staked and 'title' was held. These rules were then enforced by miner courts."9
  • 1849: Congress creates the Department of the Interior. The Senate vote in favor is fairly narrow because of opposition from members who fear federal encroachment on state affairs. Once created, Interior becomes known as the "department of everything else" for its many disparate activities.
  • 1850: The first federal railroad land grant is for a line from Chicago, Illinois to Mobile, Alabama.10
  • 1850: The Swamp Act leads to the transfer of 50 million acres of federal land to state governments over time. Many of the transfers stem from the states cheating the federal government into handing over ineligible non-swamp land. 11
  • 1862: The Homestead Act allows western settlers to receive title for up to 160 acres of free land if they live on it for five years and make improvements. The Republican Party adopts homesteading in its 1860 election platform, and passage is made possible by the secession of Southern states from the union. This important law allows almost 290 million acres of federal land to be privatized in coming decades. However, the 160-acre allotments are too small to make economic sense in many of the arid regions in the West. Thus, "there was no legal way to acquire the large acreage required for a viable ranch, timber operation, or other production unit in the West."12 Congress is slow in rectifying the problem with the result that western land acquisition is subject to rampant fraud and various distortions as settlers try to assemble larger and more efficient parcels of land.
  • 1862: The Pacific Railroad Act provides land grants and low-interest loans to the Central Pacific and Union Pacific companies to build a railroad connecting the eastern states to the West Coast. Congress grants 128 million acres of land to railroad companies between 1862 and 1871.13 The process, which is overseen by Interior, is hit by the Credit Mobilier scandal in 1872.14 Credit Mobilier—a construction company that is financially controlled by leaders of the Union Pacific Railroad—makes large profits at the taxpayers' expense.
  • 1862: The Morrill Act provides grants of federal land to the states. The states are to use the proceeds of land sales to create colleges focused on agricultural studies.
  • 1866: Mining laws of 1866 and 1872 officially open federal lands in the West to mining, although mining on these lands is already widely practiced. The new federal laws generally follow the rules and property rights developed by miners themselves in prior decades.
  • 1871: Congress abandons the policy of making new treaties with Indian tribes as if they were fully sovereign governments.
  • 1871: Congress creates the U.S. Fish Commission to study the stocks of commercial fish in the nation's lakes and on the ocean coasts. The agency is renamed the Bureau of Fisheries in 1903, and it is combined with the Bureau of Biological Survey to become Interior's Fish and Wildlife Service in 1940.
  • 1872: Congress creates the first national park, Yellowstone, which is administered by Interior.
  • 1873: Congress transfers oversight of U.S. overseas territories from the State Department to Interior. Over time, Interior becomes responsible for the territories of Alaska, Hawaii, the Virgin Islands, Puerto Rico, Guam, and American Samoa.
  • 1875: Interior Secretary, Columbus Delano, resigns from office in the face of various corruption scandals. An official history of Interior notes that "corruption in the Indian Service rose to new heights" under Delano.15 He apparently secures favors for his son, takes bribes for land grants, and oversees a department that has an array of bogus clerks and agents on the payroll.
  • 1879: The U.S. Geological Survey is created within Interior to research and map the nation's lands, thus consolidating activities that had taken place within both Interior and the War Department.
  • 1880s: The Bureau of Indian Affairs expands to more than 2,000 employees who oversee the federal relationship with Indians living on reservations. The federal approach is to "civilize" the Indian, which "meant transforming him into a Christian farmer embracing the values of 19th-century white America."16 That misguided policy was combined with a federal Indian bureaucracy that was totally inept. During this era, "the Indian Bureau operated under constant and often well-founded criticism of corruption and inefficiency in its handling of the millions of dollars in supplies purchased each year for the reservations," notes an official history.17
  • 1887: The Dawes or General Allotment Act provides Indian families with an individual portion of tribal land for homesteading in an effort to assimilate them into American society. These land grants are held in trust by the federal government for 25 years. "Excess" lands on reservations are sold to non-Indian settlers. The Dawes Act undercuts tribal governments, and it helps cause a huge shrinkage of Indian tribal lands from 138 million acres in 1887 to 48 million acres in 1934.18 Allotment represents an effort "to destroy tribes and their governments and to open Indian lands to settlement by non-Indians and to development by railroads."19
  • 1890: Interior's Pension Bureau has about 6,000 employees, whose main role is to administer the benefits provided to Civil War veterans.
  • 1891: The Forest Reserve Act allows presidents to set aside protected forest areas on federal lands. These reserves are initially managed by Interior, but are moved to the Department of Agriculture's Forest Service in 1905. The Forest Reserve Act reflects the Progressive movement's efforts to reverse the long-standing policy of transferring federal lands to state governments and the private sector. However, efficiently managing vast areas of land from Washington turns out to be much more difficult than the Progressives envision.20
  • 1902: The Reclamation Act passes with the support of President Theodore Roosevelt and after years of lobbying by special interest groups such as the railroads. The Act creates a Reclamation Service—later the Bureau of Reclamation—to construct dams and other infrastructure to bring water to arid western lands. Reclamation projects are distributed across the states based on political factors, and with little regard to choosing the projects with the highest returns. The Reclamation Act requires the full repayment of project costs by water users—generally farmers—but only a small fraction of the costs are ever repaid.21
  • 1916: Congress creates the National Park Service, which brings together the management of 14 national parks and 21 national monuments.22 The agency's first director, Stephen Mather, argues that the federal government should manage only those parks that are unique and nationally significant, with the rest managed by state and local governments.23 However, many of Mather's successors are empire builders, and they encourage Congress to acquire as many sites in as many states as possible. Today, the National Park Service is hugely bloated with hundreds of sites that would be better managed by state, local, or private owners.
  • 1920: Congress passes the Mineral Leasing Act, which forms the basis of modern rules for extracting oil, gas, and coal resources on federal lands. The Act enables the government to raise substantial bonus payments, rental payments, and royalties from energy production on its lands.
  • 1922: News of the Teapot Dome bribery scandal breaks. The Teapot Dome is a federal oil reserve in Wyoming. Investigations reveal that Interior Secretary Albert Fall has secretly leased the Teapot Dome reserve and California's Elk Hills reserve to particular oil executives and received a $409,000 payoff in return. Fall is convicted and sentenced to a year in prison.24
  • 1928: Congress authorizes the building of Boulder Dam, later named Hoover Dam. Originally, the beneficiaries of western dam projects were supposed to pay back the Bureau of Reclamation's costs of construction. With the approval of Hoover Dam, however, "large appropriations began to flow to Reclamation from the general funds of the United States."25
  • 1930: The blue ribbon Garfield Commission supports President Herbert Hoover's call to transfer ownership of millions of acres of western lands to the states. However, the proposal fails in Congress and for similar reasons that such efforts would fail in the 1970s and 1980s. Ranchers and other special interests in the West are subsidized under existing federal rules, and they are concerned about how they would fare under changes to land ownership.26
  • 1933: Harold Ickes becomes Secretary of the Interior and holds the position until 1946. Ickes is a key architect of the New Deal and also head of the Public Works Administration. The new Interior building in Washington costing $12.7 million is one of the PWA's first projects.
  • 1934: The Taylor Grazing Act creates the Grazing Service and authorizes the government to put 80 million acres of land into grazing districts, requiring users to get permits, pay fees, and follow federal regulations.27 The law ends the homesteading era, under which the goal had been to transfer federal lands in the West to private or state ownership.
  • 1934: The Indian Reorganization Act reverses the assimilation goal of the 1887 Dawes Act, and encourages the development of tribal governments and tribal constitutions. Federal policies during the 1930s are called the Indian New Deal.
  • 1940: The U.S. Fish and Wildlife Service is created from the Bureau of Fisheries and the Bureau of Biological Survey. The agency oversees a large array of wildlife refugees that the government has been accumulating since 1903. Its responsibilities encompass migratory birds, endangered species, marine mammals, sport fisheries, wildlife research, and recreational activities.
  • 1946: President Harry Truman uses an executive order to create the Bureau of Land Management (BLM) out of Interior's General Land Office and the Grazing Service. BLM's responsibilities encompass cattle grazing, timber, mineral resources, wildlife habitat, cultural sites, recreation, and other activities. Today, the agency has jurisdiction over more than 10 percent of the total land area of the United States.28
  • 1953: Congress changes direction regarding Indian policies, and passes legislation aimed at assimilating Indians and eliminating benefits for tribes. In subsequent years, more than 100 tribes lose federal aid and have their tribal governments dissolved with tribal resources distributed to individual members.29
  • 1961: Stewart Udall becomes Interior Secretary and encourages passage of a flood of environmental legislation during his eight years in office, including the Clean Air Act of 1963, the Wilderness Act of 1964, the Land and Water Conservation Fund Act of 1965, the National Historic Preservation Act of 1966, and the Wild and Scenic Rivers Act of 1968.
  • 1968: Congress passes the Indian Civil Rights Act, which begins to reverse the policies begun in 1953 of encouraging assimilation. The new policy direction for Indian tribes is called the Era of Self Determination. President Richard Nixon supports the new policy in a 1970 message, which promotes the self-determination of Indian tribes and promises tribes continued federal support.30
  • 1968: Congress authorizes the massive Central Arizona Project to channel water with huge pumps and aqueducts from the Colorado River to Phoenix, Tucson, and surrounding areas. The project is one of numerous large Bureau of Reclamation projects that don't make much sense from an economic or an environmental perspective.31
  • 1969: The phrase "Washington Monument strategy" is coined when the National Park Service shuts downs the Washington Monument in a successful effort to persuade Congress to restore cuts to its budget.32
  • 1971: President Richard Nixon signs the Alaska Natives Claims Settlement Act, giving 44 million acres and $962 million to local native groups and 13 larger native corporations in Alaska.33
  • 1973: Congress passes the Endangered Species Act, which expands federal power over private lands. The law's basic approach is to put most of the cost of endangered species recovery onto the owners of the land the animals happen to live on. As such, it creates perverse incentives for landowners to destroy or minimize wildlife on their lands before the government effectively expropriates it.34 The law is administered by Interior's Fish and Wildlife Service.
  • 1973: Followers of the American Indian Movement (AIM) stage a 71-day occupation and stand-off with law enforcement officials at Wounded Knee, South Dakota.35 Led by Russell Means and others, AIM publicizes a position paper describing how to reform federal Indian policies and abolish the Bureau of Indian Affairs.36
  • 1976: The Bureau of Reclamation's Teton Dam in Idaho collapses a year after it was built. The dam suffered from shoddy engineering, and it was built based on a flawed economic analysis.37
  • 1976: The Federal Land Policy and Management Act promotes the retention of federal lands and creates new regulations for lands overseen by the Bureau of Land Management. Many westerners feel that the law is another federal power grab, and they launch the Sagebrush Rebellion aimed at transferring federal lands to state ownership.
  • 1977: President Jimmy Carter tries to end funding for a "hit list" of 19 water projects being pursued by the Bureau of Reclamation and the Army Corps of Engineers. Carter examines the environmental and economic effects of the projects, and he concludes—probably rightly—that they are boondoggles. However, Carter misplays the politics of the issue, and his proposed spending cuts go nowhere in Congress.38
  • 1977: Congress creates the Office of Surface Mining Reclamation and Enforcement to oversee state regulation of surface coal mines.
  • 1979: The Nevada legislature passes the Sagebrush Rebellion Act aimed at transferring federal lands in the state to the state government. The Sagebrush Rebellion in Nevada and other states is spurred by resentment over increasing federal control over western lands.39 However, the Rebellion fizzles out when ranchers and other users of federal lands realize that they might not receive the same level of benefits if there is a change in land ownership.
  • 1979: Senator Orrin Hatch of Utah and other members of Congress introduce legislation to transfer some federal lands to state control.
  • 1980: President Jimmy Carter signs the Alaska National Interest Lands Conservation Act, which adds more than 47 million acres to the National Park System and nearly 54 million acres to the National Wildlife Refuge System.40
  • 1982: The Reagan administration proposes to privatize unneeded federal lands. President Ronald Reagan's Council of Economic Advisors spearheads the effort, and Reagan signs an executive order creating a Property Review Board to identify lands to be sold.41 His budget chief, David Stockman, supports the plan as a way to reduce the federal deficit.42 However, Interior Secretary James Watt is an "ardent foe" of privatization, and the plan runs into opposition from western interests worried that their privileges with respect to federal lands will be altered.43
  • 1982: The Minerals Management Service is established to handle federal revenue collection stemming from onshore and offshore energy and mineral extraction. After major scandals, the agency is split up in 2010 into the Bureau of Ocean Energy Management, Regulation, and Enforcement and the Office of Natural Resources Revenue.
  • 1994: Interior Secretary Bruce Babbitt proposes to increase Bureau of Land Management grazing fees for ranchers, which are set far below market levels. However, he faces strong opposition and withdraws the plan.44
  • 1995: Congress abolishes the Bureau of Mines, which had been established in 1910. The bureau acted essentially as an industrial research organization for the mining industry.
  • 2006: Scandals at Interior lead the department's Inspector General, Earl Devaney, to declare that it suffers from "a culture of managerial irresponsibility," including cronyism and widespread ethical failures.45 Devaney charges that "short of a crime, anything goes at the highest levels of the Department of Interior."46
  • 2006: Jack Abramoff pleads guilty to various crimes relating to his lobbying activities, including his efforts to gain favors from officials at the Bureau of Indian Affairs (BIA). Abramoff had been on President George W. Bush's transition team for Interior, and he had become friends with the department's deputy secretary, Steven Griles.47 Abramoff's lobbying goal was to use his BIA contacts to secure favors for Indian clients related to tribal recognition and tribal gaming. Both Abramoff and Griles were sentenced to jail for their respective roles in the scandal.
  • 2008: Government ethics reports condemn leaders at Interior's Minerals Management Service for various conflicts of interest.48 Interior's Inspector General reports that MMS employees have close relationships with, and have received gifts from, employees of the energy firms they were supposed to be regulating.49 MMS failures become even more evident in the aftermath of the 2010 Deepwater Horizon oil spill in the Gulf of Mexico.
  • 2009: President Barack Obama approves a $3.4 billion class action settlement for more than 300,000 Indian trust fund claims after a long-running dispute.50 Cobell v. Salazar had charged the Bureau of Indian Affairs (BIA) with decades of mismanagement of Indian trust funds.51 The 1887 Dawes Act was supposed to set up trust funds to receive royalty and lease payments for the use of Indian lands, but the government's handling of these funds was a shambles from the beginning. U.S. District Court Judge Royce Lamberth, who was overseeing the case, concluded that BIA management was "fiscal and governmental irresponsibility in its purest form."52 He said that the BIA "has served as a gold standard for mismanagement by the federal government for more than a century."53
  • 2011: The Government Accountability Office reports that Interior has between $13.5 billion and $19.9 billion of deferred maintenance costs.54 There are frequent complaints that the national parks and other Interior lands and facilities suffer from deterioration and neglect. The problem is that Interior agencies have accumulated far more assets than they can manage efficiently.
  • 2011: The Department of the Interior manages more than 500 million acres of land, which is about one-fifth the land area of the United States.55 The department has about 70,000 employees and 2,400 offices across the nation. It has gross budget outlays of $20.5 billion and net outlays after offsetting receipts of about $13 billion in fiscal 2011.56

1 Robert M. Utley and Barry Mackintosh, "Department of Everything Else: Highlights of Interior History," Department of the Interior, 1989,

2 James Muhn and Hanson R. Stuart, Opportunity and Challenge: The Story of BLM (Washington: Department of the Interior, September 1988), Chapter 1,

3 Robert H. Nelson, Public Lands and Private Rights (Lanham, Maryland: Rowman and Littlefield, 1995), p. 32.

4 Gary Libecap, "Property Rights and Federal Land Policy," in Douglass C. North, ed. Government and the American Economy (Chicago: University of Chicago, 2007), p. 94.

5 Department of the Interior, "What is the BIA's History,"

6 Connie F. Erickson, "Many Nations in One: A History of Federal Indian Policy," Montana Legislative Council, September 1993), p. 7,

7 Richard W. Wahl, Markets for Federal Water: Subsidies, Property Rights, and the Bureau of Reclamation (Washington: Resources for the Future, 1989), p. 13.

8 Richard W. Wahl, Markets for Federal Water: Subsidies, Property Rights and the Bureau of Reclamation (Washington: Resources for the Future, 1989), Table 1.2.

9 James Muhn and Hanson R. Stuart, Opportunity and Challenge: The Story of BLM (Washington: Department of the Interior, September 1988), Chapter 1,

10 Robert H. Nelson, Public Lands and Private Rights (Lanham, Maryland: Rowman and Littlefield, 1995), p. 15.

11 Robert H. Nelson, Public Lands and Private Rights (Lanham, Maryland: Rowman and Littlefield, 1995), p. 20.

12 Robert H. Nelson, Public Lands and Private Rights (Lanham, Maryland: Rowman and Littlefield, 1995), p. 19.

13 James Muhn and Hanson R. Stuart, Opportunity and Challenge: The Story of BLM (Washington: Department of the Interior, September 1988), Chapter 1,

14 Edward Winslow Martin, "A Complete and Graphic Account of the Crédit Mobilier Investigation," Continental Publishing Company and National Publishing Company, 1873,

15 Robert M. Utley and Barry Mackintosh, "Department of Everything Else: Highlights of Interior History," Department of the Interior, 1989,

16 Robert M. Utley and Barry Mackintosh, "Department of Everything Else: Highlights of Interior History," Department of the Interior, 1989,

17 Robert M. Utley and Barry Mackintosh, "Department of Everything Else: Highlights of Interior History," Department of the Interior, 1989,

18 Tom Hoffman and Gwen-Torges Hoffman, "Bureau of Indian Affairs," in George T. Kurian, ed. A Historical Guide to the U.S. Government (Oxford, England: Oxford University Press, 1998), p. 310.

19 "Allotment," in "Encyclopedia of Oklahoma History and Culture," Oklahoma Historical Society, 2007,

20 For a discussion of shortcomings in federal land management, see Robert H. Nelson, Public Lands and Private Rights (Lanham, Maryland: Rowman and Littlefield, 1995).

21 Congressional Budget Office, "Water Use Conflicts in the West," August 1997, p. 13.

22 For background, see James F. Kieley, A Brief History of the National Park Service (Washington: Department of the Interior, 1940),

23 Barry Mackintosh, "National Park Service," in George T. Kurian, ed. A Historical Guide to the U.S. Government (New York: Oxford University Press, 1998), p. 418.

24 Leslie E. Bennett, "One Lesson From History: Appointment of the Special Counsel and the Investigation of the Teapot Dome Scandal," Brookings Institution, 1999,

25 Bureau of Reclamation, "Brief History," January 2011, p. 4,

26 Kendrick A. Clements, "Herbert Hoover and Conservation, 1921-33," The American Historical Review 89, no. 1 (February 1984), p. 85.

27 Robert M. Utley and Barry Mackintosh, "Department of Everything Else: Highlights of Interior History," Department of the Interior, 1989,

28 Department of the Interior, "DOI Quick Facts,"

29 Connie F. Erickson, "Many Nations in One: A History of Federal Indian Policy," Montana Legislative Council, September 1993, p. 22,

30 President Richard Nixon, "Special Message on Indian Affairs," July 8, 1970.

32 George B. Hartzog, Jr. Battling for the National Parks (Mt. Kisco, NY: Moyer Bell, 1988), p. 155.

33 "Alaska Native Claims Settlement Act," Digest of Federal Resource Laws of Interest to the U.S. Fish and Wildlife Service,

34 Robert J. Smith, "The Endangered Species Act: Saving Species or Stopping Growth?" Regulation 15, no. 1 (Winter 1992). And see Jonathan H. Adler, "Anti-Conservation Incentives," Regulation 30, no. 4 (Winter 2007-2008).

35 "History-Incident at Wounded Knee," U.S. Marshals Service,

36 The position paper is "The Trail of Broken Treaties," American Indian Movement,

37 Marc Reisner, Cadillac Desert (New York: Penguin Books, 1993), pp. 385-410.

38 Marc Reisner, Cadillac Desert(New York: Penguin Books, 1993), Chapter 9.

39 Robert H. Nelson, Public Lands and Private Rights (Lanham, Maryland: Rowman and Littlefield, 1995), p. 175.

40 Robert Durant, "Department of the Interior," in George T. Kurian, ed. A Historical Guide to the U.S. Government (Oxford, England: Oxford University, 1998), p. 318.

41 The Council of Economic Advisor's Steve Hanke was one of the leaders of Reagan's privatization push. See Steve H. Hanke, "The Privatization Debate: An Insider's View," Cato Journal 2, no. 3 (Winter 1982).

42 Robert H. Nelson, Public Lands and Private Rights (Lanham, Maryland: Rowman and Littlefield, 1995), p. 187.

43 Steve H. Hanke, Letter to the Editor, Regulation 9, no. 1 (January-February 1985).

44 John H. Cushman, Jr., "Administration Gives Up on Raising Grazing Fees," New York Times, December 22, 1994.

45 Edmund L. Andrews, "Interior Official Assails Agency for Ethics Slide," New York Times, September 14, 2006.

46 Edmund L. Andrews, "Interior Official Assails Agency for Ethics Slide," New York Times, September 14, 2006.

47 Sean Alfano, "Dark Days for Bureau of Indian Affairs,", June 21, 2006.

48 Department of the Interior, Inspector General, "Investigative Report of MMS Oil Marketing Group-Lakewood," August 19, 2008. And see Department of the Interior, Office of Inspector General, "Investigative Report of Gregory W. Smith," August 7, 2008.

49 Juliet Eilperin and Madonna Lebling, "MMS's Troubled Past," Washington Post, May 29, 2010.

50 Various documents are available at "Cobell v. Salazar Settlement," House of Representatives, Natural Resources Committee,

51 Patrick Reis, "Obama Admin Strikes $3.4B Deal in Indian Trust Lawsuit," New York Times, December 8, 2009.

52 The quotation is from Lamberth's opinion in the case, which is available at

53 Quoted in Sheryl McCarthy, "U.S.'s Rape of the Indians Continues Still Today," Newsday, September 19, 2003.

54 Government Accountability Office, "Department of the Interior: Major Management Challenges," GAO-11-42T, March 1, 2011, p. 15.

55 See Department of the Interior, "Quick Facts,"

56 Budget of the United States Government, Fiscal Year 2012, Analytical Perspectives (Washington: Government Printing Office, 2011), Table 33-1.


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