Taking Indian Land Without Compensation

The United States bought Alaska from the Russians in 1867. The Russians had never attempted to force the Alaska natives to recognize Russian ownership, nor had they made any treaties with the natives, nor had they purchased any land from the natives. The Russians had never had any effective control over the natives and the total Russian population in Alaska was less than 800, living in four very heavily fortified towns. In the transaction, the natives were barely mentioned and there was more concern for the protection of those Russians who might want to remain.  

The Tlingit watched the ceremonial transfer from Russia to the United States at New Archangel (present-day Sitka) with great interest. Since Indians were not allowed in town, the Tlingit watched from their canoes in the harbor.

Under an international law known as the Discovery Doctrine, the Indian nations of Alaska had no say in this transfer. The Discovery Doctrine, which currently forms the basis of American Indian law, says that Christian nations, such as the United States, have a right to govern all non-Christian nations. Thus, the United States ignored not only the sovereignty of Indian nations, but also the rights of these nations to access the resources on the lands and seas which they had traditionally used.

At the time the United States took over Alaska there were an estimated 31,000 Natives in the territory and about 300 non-Indians, most of whom lived in what would become Sitka. The Americans were more concerned with the rights of the non-Indians than with those of the Indians.

In 1884, Congress passed the Alaska Organic Act which specified that native use of the land would not be disturbed, but it did not give them title to the land. It was the feeling of Congress that this Act was needed for the development of Alaska’s extensive resources, including mineral rights and timber.

Following World War II, the United States entered into a period in which a great deal of timber was needed to provide the lumber for the houses which were being built. To provide timber for the housing boom, the United States Department of Agriculture authorized timber harvest on the Tongass National Forest in Alaska. There was neither concern nor acknowledgement that the timber which was harvested was on lands which were traditionally claimed by the Tee-Hit-Ton, a subgroup of the Tlingit.

The Tee-Hit-Ton brought action in the Court of Claims for compensation under the Fifth Amendment for timber taken from tribal lands. The tribe argued that it had full proprietary ownership of the timber. The federal government, on the other hand, asserted that if the Tee-Hit-Ton had any rights at all, they were to use the land at the government’s will.

The Court of Claims found that the Tee-Hit-Ton were an identifiable group residing in Alaska and that its interests in lands prior to the purchase of Alaska by the United States were “original Indian title.” Since Congress didn’t recognize the tribe’s legal rights regarding property ownership, the Court dismissed the case.  

In 1954, the United States Supreme Court heard arguments in the Tee-Hit-Ton case. The government argued that under international law Christian nations can acquire lands occupied by heathens and infidels. It was an argument made by the United States government on the basis of the Christian religion. In their argument, the United States government not only cited the nineteenth century case of Johnson v M’Intosh, but also the Papal bulls of the fifteenth century and the Old Testament from the Bible.

In 1955, the Supreme Court announced its decision which denied the Tee-Hit-Ton any compensation for the taking of the timber. According to the Court:

“The Christian nations of Europe acquired jurisdiction over newly discovered lands by virtue of grants from the Popes, who claimed the power to grant Christian monarchs the right to acquire territory in the possession of heathens and infidels.”

The Supreme Court denied compensation and asserted:

“No case in this Court has ever held that taking of Indian title or use by Congress required compensation.”

In order to be compensated under the Fifth Amendment, the tribe would have needed some prior acknowledgement of land ownership through a treaty, a statute, or an executive order. The Alaska Organic Act did not recognize aboriginal land ownership.

In its finding, the Court views the Indians as nomads who have not developed the land:

“The Tee-Hit-Tom were in a hunting and fishing stage of civilization, with shelters fitted to their environment, and claims to rights to use identified territory for these activities as well as the gathering of wild products of the earth.”

The Tee-Hit-Ton case reaffirmed the Discovery Doctrine as the basis for U.S. law with regard to Indian nations. It reaffirmed this Christian doctrine as the principle to be used in judging American Indians and discounted American Indian history and religious traditions. While denying that Indians have any legal rights as pagan nations, the Court also stated:

The American people have compassion for the descendants of those Indians who were deprived of their homes and hunting grounds by the drive of civilization. They seek to have the Indians share the benefits of our society as citizens of this Nation. Generous provision has been willingly made to allow tribes to recover for wrongs, as a matter of grace, not because of legal liability.

Lindsay Earls, American heroine

( – promoted by navajo)

  On June 27, 2002, the US Supreme Court rendered a verdict on a case brought by Lindsay Earls, a member of the Cherokee Nation, whom I refer to as a great American heroine. Even though she is an Oklahoma resident, her case received a great deal of coverage in my region (Vermont/New Hampshire border) as she was by then a student at Dartmouth College (whose medical center I am employed at).

I wrote about this several years ago; alas, several links which I cite here no longer work. But here first is her story of courage, followed by what she is doing today.

In 1999, Lindsay Earls was a 16 year-old junior at Tecumseh High School (about 40 miles southeast of Oklahoma City) and was a self-described “goody two-shoes”; being a member of an academic quiz team and a choir singer. One day she was called out of choir practice to submit to a random urine test for drugs; based on a 1998 school board policy that required all students in grades 7 – 12 to submit to a urine test before joining any extracurricular activities.

In order to preserve her right to participate, she complied with the drug testing (and always passed) but filed a lawsuit claiming that the policy violated the Fourth Amendment’s prohibition against unreasonable search/seizure. Her position was denied by the district court, then supported by the Tenth Circuit Court of Appeals and then reached the US Supreme Court in March, 2002.

Lindsay Earls had reason for hope, since the most relevant Supreme Court precedent had to do with a 1995 case called Vernonia School District vs. Acton. This involved a school district that had experienced problems with drugs (performance-enhancing in addition to recreational use, if I recall correctly) on its athletic teams. It instituted a policy that called for random drug-testing of student-athletes only (due to the danger involved in contact sports). Though I regret anytime that we move away from probable cause to guilty-until-proven-innocent: that ruling at least seemed to have been decided judiciously.

By contrast, the Tecumseh policy was not based on a response to drug usage among students involved in extra-curricular activities, and it applied to members of, say, the debate team as well.

Lindsay Earls endured some rather snide remarks from people in her home state who trotted out the old police-state-like “if you have nothing to hide…..” argument, despite her passing the test. Particularly telling was this quote from someone in Congress:

Indiana Rep. Mark Souder (R) said the court’s ruling should drive an expansion of testing nationwide and will not hurt the privacy of students. The testing “is only burdensome on those who want to waste their lives getting high,” he said.

Yes ….. that Mark Souder …. he of marital infidelity fame .. infamy.


She also had to endure this from Justice Anthony Kennedy whom I regarded as a genuine hero himself in “Lawrence vs. Texas”:

Justice Anthony Kennedy drew gasps from the courtroom audience when he appeared to personally attack plaintiff Lindsay Earls. Kennedy posed a hypothetical with one school that had drug testing and one that did not — “the druggie school,” he called it. “Every parent” would want to send his children to the first school”, Kennedy told plaintiff’s attorney Graham Boyd of the ACLU’s Drug Policy Litigation Project, but then added dismissively, “Well, perhaps not your client”.

On that fateful day of June 27, 2002, the US Supreme Court overturned the Court of Appeals case and ruled against Lindsay Earls by a 5-4 margin. This ruling sadly seemed to up-the-ante for the guilty-until-proven-innocent standard, as the court seemed to dismiss the fact that the high school in question had no history of drug use among those involved in extra-curricular activities, and now stretched hard to say that anyone who did participate had no right to expect privacy.

One wonders if a future court will take the next logical step and endorse testing for all students (on a loco-parentis basis). Paul Clement – then the deputy solicitor general for the Bush administration – felt school-wide drug testing would be constitutional and has said so in court. Yet as a  commentator for the Daily Texan noted at the time (sadly which is no longer on-line), “But obviously he’ll settle for extracurricular activities now, since it makes for an easier case“.

If there are saving graces to this story (besides the courage of this young woman) it would be:

(a)  Many school districts have not adopted these policies – some doubt their effectiveness, while the majority have decided the cost to be too much. And perhaps in part because …..

(b)  Those authorities realize that a 5-4 majority may fall some day; perhaps a future justice may echo the words of Justice Kennedy when he famously declared that the precedent that he voted to overturn in Lawrence vs. Texas was, “wrongly decided then, and it is still wrong“, and

(c)  Some conservatives felt uncomfortable by the decision, also – consider these words from Debra Saunders – first written in a Town Hall(!) column entitled “Want to join the chess club? Pee In a Cup”:

Liberals and conservatives should be outraged at last week’s U.S. Supreme Court ruling in favor of an Oklahoma school district’s mandatory drug testing policy for students involved in extracurricular activities. That 5-to-4 decision, written by Justice Clarence Thomas, was an assault on parental rights. Since drugs were involved, the justices felt free to indulge in judicial activism — something conservatives such as Thomas are supposed to abhor.

Finally, this story has a happy ending in that Lindsay Earls not only is a 2005 graduate of Dartmouth College, but for a few years held a position of responsibility at the Indigenous Democratic Network (as she no longer works there, this is no longer on-line):

Lindsay Earls, a member of the Cherokee Nation of Oklahoma, hails from Tecumseh, Oklahoma. While at Dartmouth, Lindsay was active in Dartmouth Civil Liberties Union and in DREAM – a Vermont-based mentoring program. Lindsay has been a recipient of the ACLU’s Youth Activism Award and the New Hampshire Civil Liberties Union’s Bill of Rights Award.

Currently she is a law student at the University of Tulsa, and this past spring gave an address sponsored by the Oklahoma ACLU on her case.

I was originally tempted to entitle this essay (Native) American heroine …. but upon reflection, I think I have the title just as it should be.

Christian Doctrine and Dehumanization

( – promoted by navajo)

The United Nations Permanent Forum on Indigenous Issues has released a report which looks at the roots of the Christian domination over indigenous peoples. Forum member Gonnella Frichner, an attorney and member of the Onondaga Nation, indicated:

The first thing indigenous peoples share is the experience of having been invaded by those who treated us without compassion because they considered us less than human.

The central theme of this Christian domination has been the Discovery Doctrine.



Christian nations have assumed that they had a right to govern the indigenous nations they encountered. This right stemmed from the legal and religious Doctrine of Discovery which declares that Christian nations have a right, if not an obligation, to govern all non-Christian nations. Once an indigenous nation had been read the Christian history of the world, even though it might be read to them in a language they did not understand, then they were obligated to be ruled by the superior Christian nation.

The Catholic Pope in 1452 laid the foundation for the Doctrine of Discovery by issuing the papal bull dum diversas which instructed the Portuguese monarchy

“to invade, capture, vanquish, and subdue all Saracens, pagans, and other enemies of Christ, to put them into perpetual slavery, and to take away all their possessions and property.”

In 1455, the Catholic Pope issued a papal bull, Romanus Pontifex, which sanctified the seizure of non-Christian lands and encouraged the slavery of natives.

A papal bull is a special kind of patent or charter issued by a pope. It is called a “bull” because of the seal (bulla) which was appended to the end of it and served to authenticate the document.

In 1500, the Spanish began using The Requirement, a document which stated that God has declared that the Pope rules all people, regardless of their law, sect, or belief. The Spanish explorers were to read the document to all non-Christian people they encountered and ask them to come forward of their own free will to convert to Catholicism or

“with the help of God we shall use force against you, declaring war upon you from all sides and with all possible means, and we shall bind you to the yoke of the Church and Their Highnesses; we shall enslave your persons, wives, and sons, sell you or dispose of you as the King sees fit; we shall seize your possessions and harm you as much as we can as disobedient and resisting vassals.”

The requirement was drawn up by Palacios Rubios, Spain’s master jurist, and provides the legal basis for the Spanish conquest of the Americas. All Spanish expeditions were required to carry a copy of the document.

The idea of a “just war” is based upon the word of Saint Augustine. Under this concept, a just war was one that was waged to right an injustice or wrong by another nation. One of these wrongs, according to the Christian view, was not being Christian. Thus, if an Indian nation were to fail to let missionaries live and preach among them, then they were committing a “wrong” which would have to be set right through a “just war.”

In 1529, Pope Clement VI wrote to King Charles of Spain:

“We trust that, as long as you are on earth, you will compel and with all zeal cause the barbarian nations to come to the knowledge of God, the maker and founder of all things, not only by edicts of admonitions, but also by force and arms, if needful, in order that their souls may partake of the heavenly kingdom”

The Discovery Doctrine as U.S. Law:

When the United States came into existence in the late 18th century, it simply followed the precedent of the English. Since the English, as a Christian nation adhering to the Doctrine of Discovery, had assumed that it had a right to rule over Indian nations, the United States simply assumed that it had acquired this same right with independence. There was no question in the minds of the founders of the new country that they had a legal and moral right to govern the Indian nations within “their” territory and, in fact, to assume that Indian territory was “their” territory.

In 1823, in Johnson and Graham’s Lessee versus McIntosh the Supreme Court found that the Discovery Doctrine gave sovereignty to England and then to the United States. Indian tribes, under this Doctrine, have a right of occupancy to the land. Christian nations, such as England and the United States, have superior rights over the inferior culture and inferior religion of the Indians. According to the Court:

“The tribes of Indians inhabiting this country were fierce savages, whose occupation was war, and whose subsistence was drawn chiefly from the forest. To leave them in possession of their country, was to leave the country a wilderness.”

Indian nations, according to the Supreme Court, have been compensated for their lands by having Christianity and civilization bestowed upon them.    

Steven Newcomb, Director of the Indigenous Law Institute, writes of the legal doctrine expressed in McIntosh:

“Based on this bizarre theory, our very existence as Indians is now assumed to be subordinate to, ruled by, and possessed as property by, the political and legal successor of the first Christian ‘discoverers,’ namely, the United States.”

The Discovery Doctrine is the legal foundation for American Indian law in the United States.

In 1954, the U.S. government, in the case of Tee Hit Ton, argued before the Supreme Court that under international law Christian nations can acquire lands occupied by heathens and infidels. The Tee Hit Ton, a Tlingit clan, were seeking to recover damages from timber taken by the United States from Indian-occupied lands. In their response the United States attorneys not only cite Johnson v McIntosh, but also the Papal bulls of the 15th century and the Old Testament from the Bible.

The Supreme Court once again affirmed the Discovery Doctrine as the foundation for the supremacy of the United States government over Indian nations. The court denied compensation and asserted:

“No case in this Court has ever held that taking of Indian title or use by Congress required compensation.”

In its finding, the Court viewed the Indians as nomads who have not developed the land:

“The Tee-Hit-Ton were in a hunting and fishing stage of civilization, with shelters fitted to their environment, and claims to rights to use identified territory for these activities as well as the gathering of wild products of the earth.”

More recently (in 2005), United States Supreme Court in City of Sherrill v Oneida Indian Nation of New York decided against the Oneida. In the decision, Justice Ruth Bader Ginsburg cited the Discovery Doctrine:

More recently (in 2005), United States Supreme Court in City of Sherrill v Oneida Indian Nation of New York decided against the Oneida. In the decision, Justice Ruth Bader Ginsburg cited the Discovery Doctrine:

“Under the ‘doctrine of discovery,’ fee title to the lands occupied by the Indians when the colonists arrived became vested in the sovereign-first the discovering European nation and later the original States and the United States.”

The United Nations:

The United Nations Permanent Forum on Indigenous Issues report looked at the Discovery Doctrine primarily in the United States. They feel that this should be the first step in a broader consideration of the Discovery Doctrine which has resulted in the dispossession and impoverishment of indigenous peoples and unlimited resource extraction from their lands. The Forum is looking at the Discovery Doctrine within the scope of the U.N. Declaration on the Rights of Indigenous Peoples.

Kuriakose Bharanikulangara, the observer for the Holy See, responded to the report by saying that the Papal Bulls had paved the way for European expansion. He insisted that the Church had upheld the rights of indigenous peoples to their ancestral lands, regardless of whether the inhabitants were Christian or not.

It’s Always About The Land, Isn’t It?

( – promoted by navajo)

Ten little Indians

One little, two little, three little Indians

Four little, five little, six little Indians

Seven little, eight little, nine little Indians

Ten little Indian boys.

Ten little, nine little, eight little Indians

Seven little, six little, five little Indians

Four little, three little, two little Indians

One little Indian boy.

(My Opinion: this song is a mix of cultural hegemony, “the concept that a diverse culture can be ruled or dominated by one group or class, that everyday practices and shared beliefs provide the foundation for complex systems of domination;” and, colonial education, “the colonizing nation implements its own form of schooling within their colonies”)

One little, two little, three little Indians

Four little, five little, six little Indians

Seven little, eight little, nine little Indians

Ten little Indian boys.

“Ten little Indian boys” discovered Columbus and this was the state of the so called “New World.”

Unlearning the Language of Conquest Scholars Expose Anti-Indianism in America. “Peaceful verses Warlike Societies” essay by James Demeo. p. 150 – 151


This evidence, drawn from history, archeology, and anthropology, speaks clearly: The New World prior to Columbus was a far less violent place than the Old World. And it can be argued that, in spite of many terrible events which followed after Columbus, the New World remained a less violent place all the way down through the centuries because of its geographical isolation from the more violent Saharasian empires…This summary suggests the general vindication of the vast majority of Native American values and peoples as standing on the peace – making side of history. Certainly, not all Indigenous American cultures fit the peaceful images given in Dances with Wolves, but it is not an exaggeration to say that the majority did.

And the Indigenous population of the so called “New World” has been significantly underestimated “for the area north of the Rio Grande;” also, a consensus of “authority” has not been reached. It is easier to sidestep the fact by saying germs did it in my opinion. Then, the “Ten little Indian boys” were victims of natural tragic causes and not victims of the extermination by the Europeans. I’ll let David Stannard talk more about “Ten little Indians.”

Native American Holocaust – Before Columbus

By the time ancient Greece was falling under the control of Rome, in North America the Adena Culture already had been flourishing for a thousand years. As many as 500 Adena living sites have been uncovered by modern archaeologists. Centered in present-day Ohio, they radiate out as far as Vermont, New York, New Jersey, Pennsylvania, Maryland, and West Virginia.

– snip –

Overlapping chronologically with the Adena was the Hopewell Culture that grew in time to cover an area stretching in one direction from the northern Great Lakes to the Gulf of Mexico, in the other direction from Kansas to New York. The Hopewell people, who as a group were physiologically as well culturally distinguishable from the Adena, lived in permanent communities based on intensive horticulture, communities marked by enormous earthen monuments, similar to those of the Adena, that the citizenry built as religious shrines and to house the remains of their dead. Literally tens of thousands of these towering earthen mounds once covered the American landscape from the Great Plains to the eastern woodlands, many of them precise, geometrically shaped, massive structures of a thousand feet in diameter and several stories high; others-such as the famous quarter-mile long coiled snake at Serpent Mound, Ohio-were imaginatively designed symbolic temples.

– snip –

Similarly, Arawak (sometimes “Taino,” but that is a misnomer, as it properly applies only to a particular social and cultural group) is the name now given to the melange of peoples who, over the course of many centuries, carried out those migrations across the Caribbean, probably terminating with the Saladoid people sometime around two thousand years ago. By the time of their encounter with Columbus and his crews, the islands had come to be governed by chiefs or caciques (there were at least five paramount chiefdoms on Hispaniola alone, and others throughout the region) and the people lived in numerous densely populated villages both ,’ inland and along all the coasts. The houses in most of these villages were similar to those described by the Spanish priest Bartolome de Las Casas:

And were the “Ten little Indians” “just as sophisticated as the Europeans,” Ms. Widdowson?


However, some Native Americans believe their ancestors originated in the Americas, citing gaps in the archaeological record and oral accounts of their origins that have been passed down through generations.

Native Americans excelled at using natural resources and adapting to the climates and terrains in which they lived. Over thousands of years distinct culture areas developed across North America. In the Northeast, for example, Native Americans used wood from the forests to build houses, canoes, and tools. Dense populations in the Pacific Northwest exploited the abundance of sea mammals and fish along the Pacific Coast. In the deserts of the Southwest, Native Americans grew corn and built multilevel, apartment-style dwellings from adobe, a sun-dried brick. In the Arctic, inhabitants adapted remarkably well to the harsh environment, becoming accomplished fishers and hunters.

Among the several hundred Native American groups that settled across North America, there existed, and still exist, many different ways of life and world views. Each group had distinctive social and political systems, clothing styles, shelters, foods, art forms, musical styles, languages, educational practices, and spiritual and philosophical beliefs.

What about the “One little Indian boy?” He knows the Ms. Widdowsons of the world are his relatives, and must be treated with the generosity of respect by sticking to the truth. Let’s forget the song for now, recognize it excludes the girls in a patriarchal exclusionary way, and get current.

Vine Deloria Jr. in God Is Red made a critical observation during the time of the Siege of Wounded Knee 1973 if memory serves (I loaned it out). He pointed out that American society bought more copies of Dee Brown’s Bury My Heart at Wounded Knee in lieu of being more aware and involved in the current situation. Overall, isn’t that still true today?

Why was there wide awareness and support for the Tibetan Monks in the general American public, and little awareness and support for American Indians protesting the  Longview Hog Farm in the general American public?

Native People are gathering to protest the construction of Longview Hog Farm near a Headstart Preschool facility that hosts Native children. They are standing in protection of the children fully aware of the environmental and health hazards hogfarms produce. South Dakota State Police violated their jurisdiction to arrest protesters peacefully gathered on a Federally Controlled BIA Road. A protester was struck by a frontloader and had to be medically evacuated by ambulance. Second Day begins as more Police aggression is anticipated and more illegal arrests may take place. Once again the “Indians” are in the way of “progress”.

And now there are “two religious rights cases on Supreme Court’s horizon.” Can an Eagle be taken for the Sundance and is it respecting religious freedom to put recycled urine and feces or “reclaimed sewage” on a sacred mountain?

Quite frankly, either the Supreme Court is for the cultures and spiritual practices surviving, or they are against it. “You cannot damage the land without damaging those who live upon it” and the Sundance, which used to be illegal, is the most sacred of the seven rites. But doesn’t this also shed light on why there was wide awareness and support for the Tibetan Monks, and little awareness and support for American Indians protesting the Longview Hog Farm? Sometimes things are simple.

Everyone was for the Tibetan Monks, which is why they had so much support. Few people were supportive of the Native People who protested the farm, because if the monks had been in South Dakota – nobody would sell the farm. It’s always about the land, isn’t it?

Indigenous Peoples Caucus meets in Geneva

“We are finding that the primary reason the U.S. did not sign on (to the Declaration on the Rights of Indigenous Peoples) is the provisions on self-determination and land ownership,”

The decolonization process

In order to eliminate the harmful, lasting effects of colonial education, post-colonial nations or territories must remove the sense of nothingness that is often present. Thiong’o insists that “To decolonize our minds we must not see our own experiences as little islands that are not connected with other processes” (The Global Education Process). Post-colonial education must reverse the former reality of “education as a means of mystifying knowledge and hence reality” (The Global Education Process). A new education structure boosts the identity of a liberated people and unites previously isolated individuals.

Lastly, “To decolonize our minds,” quit teaching this song to children.

There was the denazification of Germany, and the United States needs to decolonize itself with “a new education structure” teaching the American Indian and the Native Alaskan are not vanished races,
unless of course – it doesn’t want to.


Sad indeed, is this need to protest for the most basic human rights of “self-determination and land ownership.” Sadder, is that Americans overall support protesters there, and ignore what goes on here. But then again, it’s always about the land, isn’t it?

America’s West Bank: McCain’s Forced Navajo Relocation

Confused yet? That’s what this “legislation” was supposed to do. It was supposed to hide McCain’s involvement to steal land, and the violations of human rights remains hidden as well to the overall public. “In 1996, Congress passed a law endorsing a 75-year lease arrangement that would allow a few of the families to remain as tenants on the land. The law sanctions the relocation of families not eligible for these leases and forces the families who sign the leases to live without benefit of civil and religious rights exercised by other Americans” the UN told us. Also, PL 104-301 tells us that “the number of homesites available for lease is 112,” yet adds, “additional homesites may be made

available subject to agreement between the Hopi Tribe and homesite applicant.” Quite generous in light of the forced relocation of 10,000 Navajos. One forced relocation is a tragedy, but apparently 10,000 or more is just a statistic. The UN also told us about the loss of voting rights, the physical harassment of elders, intimidation tactics, that armed rangers visited elders at their homes and stole their property, and that their sacred sites were bulldozed – including their graveyards.

This, has been America’s West Bank:



…human rights violations and an institutionalized racism against indigenous peoples is alive and thriving in the United States…

Black Mesa project controversy rises

By Carol Berry, Today correspondent

Story Published: Oct 26, 2008

Story Updated: Oct 28, 2008

BLACK MESA, Ariz. – A push to approve a Peabody Western Coal Co. project in northern Arizona may be dividing the Hopi Tribal Council and fueling an attempted ouster of the tribal chairman.

– snip –

“They want to get it through before the presidential election and before a new administration takes office,” Nuvamsa said by telephone.

It’s always about the land, isn’t it?