Lance Walker, an oil-and-gas attorney in Oklahoma City, has posted "Not a Particle of Choctaw Blood": Samuel Caldwell's Four Citizenship Trials, 1896-1904:
This Article recovers a case that has not been examined in the scholarly literature since the tribunal that decided it closed its doors in 1904: Samuel C. Caldwell, et al. v. Choctaw and Chickasaw Nations, No. 44. Drawing on a previously unexamined 186-page case file held in the Melven Cornish Collection at the University of Oklahoma, the Article follows Samuel Caldwell’s Choctaw citizenship claim through all four of its lives — before the Dawes Commission in 1896, before the United States Court for the Central District of the Indian Territory in 1897 (first on a special master’s favorable report, then on a wholly reversed record after the Choctaw Nation alleged the suppression of a key witness’s testimony), and finally before the Choctaw and Chickasaw Citizenship Court in 1903–1904, a short-lived federal tribunal created by the Supplemental Agreement of 1902 to adjudicate exactly this kind of dispute.
The case file offers an unusually granular look at how citizenship was actually litigated during the allotment era: competing and shifting ancestry claims within a single family, testimony estimating blood quantum by appearance alone, and a disputed marriage certificate with an allegedly forged notarial seal. Caldwell himself filed for Choctaw citizenship in 1896 and Mississippi Choctaw citizenship in 1901, even as testimony elsewhere in the record described him asserting Cherokee ancestry and a rival branch of his wife’s family pursuing a separate, never-completed Cherokee claim of its own. The Article situates Caldwell’s case within the broader institutional history of the Citizenship Court’s unusual two-track jurisdiction — original jurisdiction over the tribes’ own representative suits, and appellate jurisdiction over individual claimants’ appeals — and within the vocabulary the Nations themselves used for claimants like Caldwell: not citizens, but “court citizens,” people whose standing rested on a tribunal’s say-so rather than the Nation’s own recognition.
--Dan Ernst