GHOST DANCE AND HOLY GHOST - THE ECHOES OF 19TH-CENTURY CHRISTIANIZATION POLICY IN 20TH-CENTURY NATIVE-AMERICAN FREE EXERCISE CASES

In the late nineteenth century, Native Americans were the subject of a United Stares government Christianization policy that attempted, with the help of Christian churches, to convert Native Americans to Christ ianity by assigning reservations to Christian groups for proselytizati on purposes and by suppressing Native American religious beliefs and p ractices. In this article, Professor Allison Dussias describes this Ch ristianization policy, and the attitudes, conceptual difficulties, and tensions inherent in it. Professor Dussias then examines recent Nativ e American free exercise cases, and finds a largely unacknowledged per sistence of nineteenth-century attitudes in the twentieth-century case s. Although the Establishment Clause was ignored in the nineteenth cen tury and was not an obstacle to Christianization, it has emerged in th e twentieth century as a barrier to accommodation of Native American r eligious beliefs and practices. Professor Dussias chronicles a continu ing failure by legal institutions to understand and respect Native Ame rican religious beliefs and practices.