Although opponents of land return conceded the injustice of taking the Black Hills, they made other arguments about history that potentially weakened the Lakotas' claims to the land. One of these was to characterize the Lakotas as relative newcomers to the Black Hills, who had violently displaced other tribes to secure the land for themselves. This account had two implications. First, it threatened the moral underpinning of Lakota claims to regain the Black Hills. If Lakotas were just one in a long line of conquerors, why should the Black Hills not be returned to the Crows, the Kiowas, or the Arikaras? As Elizabeth Cook-Lynn observed, the narrative of Lakota conquest "can be used to render moot any discussion of indigenous rights." Second, it called into question Lakota claims that the Black Hills were sacred land. If Lakotas "discovered" the Black Hills as late as 1776-77, how could the Black Hills have become sacred to the Lakotas in just a few decades? Several non-Lakota historians argued that the idea of the Black Hills as sacred land had been invented in the 1970s to buttress Lakotas' efforts to regain the land.
(Jeffrey Ostler, The Lakotas and the Black Hills: The Struggle for Sacred Ground, The Penguin Library of American Indian History, ed. Colin G. Calloway [New York: Viking, 2010], 182-3 [endnote omitted])
