12 Ind. C l . C m . -36
BEFORE THE INDIAN CLAIMS COMMISSION
1
THE SIX NATIONS, e t al.,
Plaintiffs,
v.
Docket No. 344
THE UNITED STATES,
Defendant,
Decided:
March 1, 1963
FINDINGS OF FACT
The Indian Claims Commission makes t h e following findings of f a c t
herein:
1. The p l a i n t i f f herein i s an i d e c t i f i a b l e group of American
Indians, r e s i d i n g within the t e r r i t o r i a l E m i t s of t h e United S t a t e s .
2.
Among the a b o r i g i r e s f i r s t encotlntered by European c o l o n i s t s
ori the North American continent were t h a s e who shared a corrmnn lacguage
i d e n t i f i e d a s "Iroquoian."
The aborigines who spoke t h i s lazgsage w e r e
generally fotlnd i n t 5 e v i c i n i t y of the- Eastern seaboard of t h e con.2iner:i.
3,
I n those e a r l i e s t contacts, t h e Lsoquoian aborlgines iden5iEied
themselves a s
'?meFive
NaZioos."
A f = e r the Tuscarora I l d i a n s wko emi-
grated f r m t h e Carolinas t o the nozzh a f f i l i a t e d themselves wizh t h e
exis2ing Iroquoian confederacy i n t h e 1720's,
t h a t confederacy vas
freq-aently r e f e r r e d t o a s "The Six Nations."
The Six Nations s o Ldanti-
f i e d were t h e Senecas, Cayugas, Onocdagas, Oneidas, Mohawks, and Tuscaroras.
From 1746, the Missisauga (Mississaga; Chippewa stock) I n d i a ~ s
were a l l i e d a s the seventh t r i b e of t h e Iroquoian confederacy o r
1 2 Ind. C I . C o r n . 86
league, but t h a t a l l i a n c e l a s t e d only u n t i l t h e outbreak of t h e French
acd I c d i a n war i n 1754.
4.
The Six Nations occasionally acted a s a u n i f i e d organization
with a s i n g l e objective, but a t o t h e r times t h e t r l b a l components of
t h e confederacy ac:ed
i n d i v i d u a l l y , o r even a t cross-purposes.
During
t h e R e v o l ~ t i o n z r yWar, t h e Orreidas and some of t h e Tuscaroras fa-ght on
t h e s i d e of t 5 e c o l o n i s t s , but t h e Seriecas, Cayugas, Onondagas, Mohawks
an< t h e r e s t of t h e Tuscaroras a l l i e d themselves w i t h t h e B r i t i s h and
focght agair?s= t h e r e b e l l i o u s c o l o n i s t s .
5:
The S i x Nations were n o t nomads.
They maintained s u b s t a n t i a l
settlements, r a i s e d crops near those settlements, hunted, and t r a d e d
p e l t s t o European c o l o n i s t s f o r arms and goods.
me
Six Nations were
w a r r h g I r r d l a ~ swho e x t e m i z a t e d , iccorporated, o r dispersed mariy of
t h e i r scrrounding neighbors.
Their wes'sward expansion was h a l t e d by t h o
Chip~ewa, while orr t h e n o r t h The S i x Nations fought s p o r a d i c a l l y with
t h e French and with Indians a l l l e d with t h e French.
6.
Among t h e Erzropean c o l o n i s t s e x p e r i e n c i ~ gc o n t a c t s w i 5 The S i x
Nations were those l i v i n g withiri t h e bo-ds
sylvania.
(%arles
of t h e P r o p r i e t a r y of Pen=-
The o r i g i n of t h i s P r o p r i e t a r y was a Royal Char2er i s s z e d by
11, King of England, t3 lJilliam Penn on March 4, 1681.
1c
strm-
mry, t h e Cfiarter granted William Penn lacd, roughly r e c t a x g u l a r , i n one
compact body bounded by t h e Delaware River on t h e e a s t , by t h e 40th
degree of northern l a t i t u d e on t h z south, by t h e 43d degree of n a r t h e r n
l a t i t u d e on t h e north, and on :he
west by a meridian l i n e five degrees
i n l o n g i t a d e west of t h e Delaware River.
Subsequent adjustments w i t h
12 Ind. Cf. Corn. 86
ot!,Fler grants issued by t h e King of ~ n g l a n dplaced t h e northern boundary
on t h e 42d, i n s t e a d of t h e 4 3 d , degree of northern l a t i t u d e .
As
adjusted, t h e northern and western boundaries of t h e Proprietary of
P e m y l v a n i a (i.e.,
t h e northwest c o m e r of Pennsylvania) formed a per-
f e c t r i g h t angle, t h e apex of which w a s a p o i n t i n Lake E r i e less than
f i v e m i l e s from shore.
7.
William Penn developed a paztern of buying land, w i t h i n t h e
c h a r t e r e d boundaries of Pennsylvania, from Indians who claimed t o own
it,
This p a t t e r n o r p r a c t i c e was n e i t h e r r e q u i r e d nor suggested i n t h e
Ropal Charter, which did n o t take Indian ownership of land i n t o accounts.
The c h a r t e r d i d n o t r e q u i r e any payment t o InrEans o r t h a t Penn pursue
any peaceful means t o come t o agreement with t h e Indians concerning u s e
and occupancy of Land i n Pennsylvania.
The p a t t s r n o r p r a c t i c e f o l l o x e d
i n Pennsylvania was a humanitarian one, designed t o minimize c o n f l i c t
and l o s s of l i f e ,
conquest
8.
It w a s less expensive than e~puLs5onof I n d i a n s by
.
Sn 1777 t h e Delegates of the s e v e r a l s t a t e s (i.e.,
colonies)
agreed t o Articles of Confederation providing f o r perpet-iai m i o n between
the t h i r t e e n states.
Among o t h e r t5ings, Article IX thereof pravided:
The United S t a t e s i n Congress assembled, &all have t h e s o l e
and e x c l c s i v e r i g h t and power of determinirg on peace acd
war,
***
The Zinited S t a t e s i n Congress assembled s'nall a l s o have t h e
s o l e and exclusi-ie r i g h t arrd pawer of
* * regulating t h e
t r a d e and managing a l l a f f a i r s with t h e I n d i a n s , n o t members
o f any of t h e S t a t e s , provided t h a t the l e g i s l a t i v e r i g k t of
any S t a t e within i t s own l i m i t s be n o t i n f r i n g e d o r v i o l a t e d
*
***
12 Ind. C 1 . Corn. 86
The A r t i c l e s of Confederation were r a t i f i e d by t h e s t a t e s , e x c e p t i n g
Maryland, i n 1778 and 1779.
Maryland withheld r a t i f i c a t i o n , and conse-
quently t h e A r t i c l e s of Confederation did not take e f f e c t , u n t i l 1781.
Maryland refused t o r a t i f y u n t i l t h e s t a t e s whose land claims embraced
t h e Northwest T e r r i t o r y ceded t h e i r western claims t o t h e United S t a t e s .
The Northwest T e r r i t o r y comprised lands n o r t h and west of t h e Ohio River,
and New York and Mzssachusetts professed overlapping claims t o l a n d s
there.
New York ceded i t s claims t o land i n t h e Northwest T e r r i t o r y
t o t h e United S t a t e s i n 1781, by v o l u n t a r i l y l i m i t i n g t h e western bounda r y of New York S t a t e t o a meridian l i n e twenty miles west of h'iagara
i n t e r s e c t i n g , on t h e n o r t h and south, by t h e 45th degree of n o r t h e r n
l a t i t u d e and t h e Pennsylvania-New York boundary, r e s p e c t i v e l y .
-'"%
-29
In
1785, Massachusetts ceded i t s claims t o land i n t h e Northwest T e r r i t o r y
t o t h e United S t a t e s , adopting s u b s t a n t i a l l y t h e western boundary s p e c i f i e d by New York f o u r years e a r l i e r .
9.
The s t a t e s 1 cessions t o t h e United S t a t e s of land claims i n
t h e Northwest T e r r i t o r y comprised t h e f i r s t land of t h e f e d e r a l p u b l i c
domain.
Lands t o t h e e a s t which were n o t ceded by t h e s t a t e s t o t h e
United S t a t e s remained t h e property of t h e s e v e r a l s t a t e s , i n d i v i d u a l l y ,
and never became p a r t of t h e f e d e r a i public domain.
10.
T h e . t r e a t y of peace between England and t h e United S t a t e s ,
marking t h e end of t h e Revolutionary War,. was concluded a t P a r i s on September 3, 1783.
It made no r e f e r e n c e t o England's I n d i a n a l l i e s and d i d
n o t provide f o r amicable r e l a t i o n s between t h e h c s t i l e I n d i a n s and t h e
new sovereign n a t i o n , t h e United S t a t e s of America.
The n e c e s s i t y f o r
a peace t r e a t y between t h e United S t a t e s and t h e I n d i a n s was c o n c u r r e n t
12 Ind. C l . C a m . 86
i n time with the d e s i r e s of the s t a t e s of New York a i d Penrrsylvania t o
negotiate with the--Indians concerning land purchases.
11. I n 1783, t h e Continental Congress passed a Resolution recognizing the need for negotiations with t h e l a t e l y h o s t i l e Indians.
In
t h e same year, the General Assembly of t h e S t a t e of Pennsylvania advised
Congress t h a t the s t a t e intended t o negotiate with Indian nations adjoining Pennsylvania f r o n t i e r s concerning land purchases.
It was u l t i m a t e l y
determined t h a t representatives of New York, Pennsylvania, t h e United
.-
S t a t e s , and The Six Nations would meet a t Fort Stan-
i n October of
1784, The Resolution passed by Congress provided i n p a r t :
That t h e commissioners f o r holding the convention with t h e
Indians under the a c t of t h e f i f t e e n t h day of October i n s t a n t
give n o t i c e t o t h e supreme executive of t h e S t a t e of Pennsylvania, of t h e time and place of holding such t r e a t y , t o
the end, t h a t t h e persons t o be appointed by t h a t S t a t e , f o r
purchasing lands within the limits thereof, a t t h e expence
of the s a i d S t a t e , may attend f o r the s o l e purpose of making
such purchase, a t t h e time and place appointed f o r holding
t h e s a i d treaty: and t h e commissioners on t h e p a r t of t h e
United States, a r e instructed t o give every a s s i s t a n c e i n
t h e i r power, t o t h e commissioners who may be appointed on
t h e p a r t of Pennsylvania, towards promoting t h e i n t e r e s t of
t h a t S t a t e , as f a r a s t h e same may consist with t h e general
i n t e r e s t of the Union , ,
.
The-United S t a t e s commissioners were appointed on March 12, 1784,
Nego-
t i a t i o n s on behalf of New York were authorized by t h a t s t a t e on A p r i l 6,
17%.
12, The New York delegation, and some r e p r e s e n t a t i v e s of The S i x
Nations, were present a t Fort Stanwyx by September 5, 1784.
The New York
delegation attempted immediate negotiations wrch The S i x Nations, but
the Indians' representatives expressed a d e s i r e t o d e a l f i r s t with t h e
United States commissioners.
The Pennsylvania and United S t a t e s delegations
12 i n d . C1. Comm. 86
-
arrived at Fort Stanwyx around the second day of October, 1784. The
Pennsylvania delegation had with it estensive trade goods to be used
in its negotiations.
13. Durlng the first few days of the conference, Indian delegates
were still arriving daily.
During this period, many of the efforts of
the United Stat~srepresentatives were devoted to inhibiting sutlersT
sales of liquor to Indians and to a continuing controversy with the
New York delegation which seemed determined to frustrate United States
negotiations. The unregulated sale of liquor to Indians frequently led
to their intoxication, with consequent detriment to the progress of the
negotiations during the first few days. The United States representatives did control the flow of liquor before serious negotiations got
a
.-: . $
under way.
14.
F i m negotiations between The Six Nations and the United States
commenced on October 17, 1784. Curing such ne~otiations,the Pennsylvania delegates attended as spectators, but did not participate in the
n2gotiations at all.
The IndiansT speaker proposed a boundary line
between property of the ZSnited States and property of the Indians. The
kited States Comissioners desmed the proposal unacceptable and, on
-
-
October 20, proposed an alternate. The Indian representatives accepted
this alternative boundary and, on October 22, 1784, a treaty of peace
between the United States and The Six Xations was concluded.
The treaty
contained the bocndary line which dropped due south from Lake Ontario
through the now city of Buffalo, New York, to the northern boundary of
Pennsylvania, due west to the western boundary of Pennsylvania, and due
s o ~ t hto the Ohio River.
The Six Nations yielded to the United States
12 Ind, C1. Comm. 86
all claims to lands west of the line so drawn, including the area popularly known as the Erie Triangle. No land within the then boundaries of
Pennsylvania was included; all c l a d pertained to lands in the federal
public d m i n by reason of states' cessions.
15. When the United States commissioners finished their business
with representatives of The Six Nations, the commissioners were asked
by the Pennsylvania delegates to introduce the latter formally to the
Indians. The Pennsylvania delegation had been instructed to extend cooperation to, and expect cooperation from, the United States commissioners.
The commissioners did agree to introduce the Pennsylvania delegates
to the Indians, and one of the commissioners, General Wolcott, stated:
We now, announce to you Col, Atlee, Mr. McClay and Col.
Johnston, three honorable gentlemen from the State of
, Pennsylvania, who have come by the consent of Congress,
as commidsioners, to transact some affairs with you, on
the part of that state, afthr the conclusion of the present
treaty, should it /The treaty between the United States
and The Six ~ a t i o n 7be concluded in a manner satisfactory
to the United states,
Colonel Atlee of the Pennsylvania delegation then addressed the Indians:
You have been now told by the honorable Commissioners from
Congress, that we attend as c ~ s s i o n e r sfrom your old
friends of Pennsylvania, to transact business with you on
the part of that state. At a prcper-season,we will produce to you our commission, and lay before you the business
committed to our charge, and we doubt not but you- will take
it under immediate consideration, and return a favourable
answer. .
16. The United States representatives took no part in the deliberations between the Pennsylvanians and Indians, except for a short ceremonial speech to the Indians on the last day of the conference, after
all details of the agreement between Pennsylvania and The Six NaZions
1 2 Ind. C1. C m m . 86
hzd been s e t t l e d .
The United Stat25 -?resentatives
did not rake p a r t
o f , o r presume t o a d v i s e , e i t h e r p a r t y t o t h e detriment of t h e o t h e r .
I n s o r e f r a i n i n g , t h e United S t a t e s r e p r e s e n t a t i v e s honored t h e s t r i c t
l i m i t s imposed upon t h e United S t a t e s i n dzallngs with I n d i a n s by t h e
n i n t h of t h e A r t i c l e s of Confederation.
17.
The C n i t e d S t a t e s , a t t h e F c r t Stanwyx conference, d i d n o t
q r c e p t o r s e i z e t h e claims of any Indians t o lands w i t h i n t h e boundaries
of t h e S t a t e of Pennsylvania.
The Uni.2ed S t a t e s d i d n o t impose any
p r e s s u r e upon t h e I n d i a n s t o g i v e p a r t i c u l a r c o n s i d e r a t i o n t o Pennsylv a n i a ' s wishes.
I n a b s t a i n i n g i m p a r t i a l l y from t h e n e g o t i a t i o n s between
~ e n n s y l v a n i aand The S i x Nations, t h e r r p r e s e n t a t i v e s of t h e United S t e t e s
accorded t h e I n d i a n s t h e f a i r n e s s and honor which t h e circumstances and
-i
t h e t i m e s demanded.
P
-. .+-
18.
A t t h e F o r t Stanwyx conferer-ce, Pennsylvania bought from The
S i x Nations, f o r a c o n s i d e r a t i o n r e c i t e d i n t h e deed from The S i x Nations,
a l l of t h e a r e a embraced by t h e i n s t a n t Claim No. 1, known h e r e i n as
Area I, The boundaries r e c i t e d i n t h e deed ~ r o v i d e di n p a r t :
. ..
DO g r a n t , bargain, s e l l , r e l e a s e , and confirm u n t o
t h e s a i d Commonwealth / ~ e n n s ~ l v a n i a 7a,l l t h a t p a r t of the
s a i d Commmwealth n c t y e t purchased of t h e I ~ d i a n swithin
t h e acknowledged l i m i t s of t h e same, B E G I b i N G on t h e s o u t h
s i d e of t h e r i v e r O f t i c , where the? western boundary of the
s t a t e of Pennsylvania c r o s s e s t h e s a i d r i v e r , n e a r S h i n g o t s
o l d Town, a t t h e moath of Bemer creek, and thence by a due
n o r t h Line t o t h e end of t h e forty-second and beginning o f
t h e f o r t y - t h i r d degrees of n o r t h l a t i t u d e , thence by a due
e a s t l i n e s e p a r a t i n g t h e f a r t y ~ s e c o n dand f o r t y - t h i r d
degree of n o r t h l a t i t u d e , t o t h e e a s t s i d e of t h e e a s t
branch of t h e r i v e r Susauehana.
...
The boundary d i v i d i n g t h e c s l o n i e s of h'ew York on t+&n o r t h and Pennsylvania
on t h e s o u t h was e s t a b l i s h e d as t h e 42d degree of n o r t h e r n l a t i t u d e and
12 Ind. C1. Corn. 86
not the 43d degree specified in the Charter to William Penn. The deed
from The Six Nations to Pennsylvania purported to convey, or quit-&aim,
II
to the latter a considerable portion of land which was actually part of
the State of New York, and the Erie Triangle.
19. When New York ceded its claims to land in the Northwest Territory to the United States, the land so ceded became the first public
domain of the United States. At the time of this cession, the western
boundary described in the deed had not been surveyed and, for years
afeeward, no o&
knew precisely &era
it lay.
In 1786 and 1787,
Pennsylvania completed the surveys of the western and northsrn boundaries
of that state. These surveys disclosed that the Pennsylvania waterfront
on Lake Erie extended only about four miles.
In 1780, Pennsylvania
authorities laid plans to buy the triangular tract,.ceded to the United
States by New York, Massachusetts, and, later, the Six Nations, which was
--
bounded by the western boundary of New York on the east, by the northern
boundary of Pennsylvania on the south, and by Lake Erie on the northwest.
This is the tract known as the ErLe Triangle (Area I-A).
It incl-ides
Presque Island, just offshore. Indians denoted as Ottawas, Chippewas,
Mississagas, and Lake Indians lived intermittently in the Erie Trianqti,
-
-
- -
and other Indians may have passed through and hunted in t h t area, from
time to time.
20-
Since the western bo-mdary of New York was not surreyed until
1790, the area embraced by the Erie Triangle was a matter of conjecture.
Pennsylvania authorities were under the impression that it comprehendsd
seven or eight hundred thousand acres. The United States sold the Erie
Triangle to Pennsylvania in 1788:
12 Ind. C 1 . Conn. 56
Whereas i t appears t h a t t h e board of t r e a s u r y i n conformity
t o t h e Act of Congress of t h e 6 t h 2une l a s t have e n t e r e d i n t o
a c o n t r a c t with t h e Delegates of t h e s t a t e of Pennsylvania i n
behalf of t h e s a i d S t a t e , f o r t h e t r a c r o f land bounded E a s t ,
agreeably t o t h e c e s s i o n of western t e r r i t o r y by t h e Seates
of Massachusetts and New York, south by Pensylvania, North
and West, by lake E r i e , and whereas t h e s a i d t r a c t i s
e n t i r e l y s e p a r a t e d from t h e o t h e r lands of the western
t e r r i t o r y , over which t h e j u r i s d i c t i o n of t h e United S t a t e s
extends; and whereas under t h e s e c i r c ~ ~ m s t a n c eist w i l l be
expedient f o r tho S t a t e of Pennsylvania t o hold and e x e r c i s e
j u r i s d i c t i o n over t h e t r a c t a f o r e s a i d , t h e r e f o r e ,
--
.I
Resolved, t h a t t h 2 United S t a t e s do hereby r e l i n q u i s h , and
Cransfer a11 t h e i r r i g h t , t i t l e an2 claim t o t h e Govsrnment
and J c r i s d i c t i o n of t h e s a i d t r a c t of land, t o t h e S t a t e
of Pennsylvania f o r e v e r ; and i t i s hereby declared and made
t h a t t h e laws and p u b l i c A c t s scf the. s a i d S t a t e s h a l l
extend over every p a r t of t h e same t r a c t t o a l l i n t e n t s and
purposes as i f t h e same had been o r i g i n a l l y w i t h i n t h e
c h a r t e r bounds of t h e s a i d S t a t e ; provided t h a t t h e Inhabit a n t s of the s a i d t r a c t s h a l l b e maintained i n a l l t h e
r i g h t s and p r i v e l e g e s which o t h e r c i t i z e n s of t h e s a i d
S t a t e of Pensylvania a r e now o r may h e r e a f t e r be c o n s t i t u t i o n a l l y e n t i c l e d t o enjoy.
-Ar
It x a s u l t i m a t e l y determined t h a t ?he Erie T r i a n ~ l e , i n c l u d i n g Presque
Fsland, embraced 202,187 a c r e s f o r which P ~ ~ s y f v a n paid
ia
t h e United
S t a t e s $151,640-25 a t t h e r a t e of $0.75 p e r a c r e .
21.
Zn 1789, Pennsylvania a c q z i r e d t5e Erie T r i a n g l e from t h e I n d i a n s .
T h i s s p e c i f i c purchase from t h o s e wfto claimed t o own i t , The S i x Kations,
was n e c e s s i t a t e d by t h e f a c t t h a t ~ e n n s y l v a n i a ' s survey i n 1787 o f h e r
own n o r t h e r n boundary d i s c l o s e d t5at t h e n o r t h e r n boundary was a p p r e c i a b l y
s o u t h of where i t had been b e l i e v e d t o have been, thus c a s t i n g doubt
upon t h e boundaries i n t e n d e d by t h e 1784 deed from t h e Indians.
The S i x
N a t i o n s d i d "grant, burgain, s e l l , remise, r e l e a s e , q u i t claim, and
assign'' t o Pennsylvania l a n d
95
12 Ind. C l . Cam. 86
. . . lying 6: being within t h e t e r r i t o r y of
Ij.
t h e United S t a t e s ,
bounded on t h e South by t h e Northrn boundary of Pennsa., on
t h e East by t h e Western l i n e o r boundary of t h e S t a t e of
New York, agreeable t o an a c t of Cession o f t h e s a i d S t a t e
of J e w York, and t h e S t a t e of Massachusetts t o t h e United
S t a t e s , and t h e North by the Southern shore o r Margin of
Lake Erie, including Presqu' i s l e and a l l t h e Bays Harbors
along t h e shore or Margin of t h e s a i d Lake E r i e from t h e
West boundary of tfie s a i d S t a t e of Pennsa,, t o where t h e
west l i n e o r boundary of t h e S t a t e of New York may c r o s s
o r i n t e r s e c t t h e southern shore o r margin of sd. Lake
Erie,
...
Inclusion of t h e y e t unknown western boundary o f New York a g a i n rendered
indeterminate t h e e x t e n t of t h e a c t u a l cession.
22.
When Pennsylvania acquired t h e E r i e T r i a n g l e from The S i x '
Nations, t h e sigoing Chiefs were under t h e impression t h a t t h e r e were
some S i x Nations v i l l a g e s i n t h a t a r e a and, by t h e F i f t h A r t i c l e of t h e
agreement, attempted t o reserve those areas t o t h e use of t h e i r people:
That a s s e v e r a l Villages belonging t o t h e s i g n i n g a i e f s s d
t h e i r people a r e now l i v i n g on t h e s a i d Conowago creek and
i n o t h e r p a r t s of t h e country supposed t o be w i t h i n t h e t r a c t
of country West of t h e West l i n e of t h e S t a t e of New York and
East of t h e l i n e through the Waters a s described i n t k e t f i i r d
And as they have no country t o remove t o from
Article
where they now l i v e , t h e s a i d c h i e f s do r e s e r v e for t h e i r own
and t h e i r people's residence, hunting and f l s h i n g , a l l .Chat
p a r t of t h e t r a c t of Country described i n t h e second A r t i c l e ,
passing from t h e Allegany River aleng t h e middle of t h e
Conowago Creek, t h e Chadochque Lake a meridian l i n e from t h e
North end of s a i d lake t o Lake E r i s .
--
It was subsequently determined t h a t t b e signing c h i e f s mkunderstood where
t h e i r v i l l a g e s were, a s a l l of t h e a t t a n p t e d r e s e r v a t i o n f e l l e n t i r e l y
w i t h i n t h e S t a t e of New York, well e a s t of t h e E r i e Triangle.
23.
O f t h e various v i l l a g e s h e r e i n a l l e g e d t o be S i x Nations towas,
only one, Conneaut, i s material.
Conneaut, l o c a t e d a t t h e j u n c t u r e o f
Conneaut Creek and Lake Erie, about t s n miles w e s t of +be E r i e T r i a n g l e
12 Ind. C1. Comm. 86
in the now State of Ohio, was not a Six Nations town at all times
material to this suit.
If Indians who lived at Conneaut traveled between
that settlement and other sites alleged to be Six Nations towns
-- and
this Commission does not now consider the validity of identifying such
other sites as Six hations towns
--
then there could have been passage
through the Erie ~ r i a n ~ l e .Any use entailed in such passage would have
been wholly transitory.
24. The Conmission finds that it has not been established by substantial evidence that The Six Nations held Indian title to Area I-A,
known as the Erie Triangle.
Artkur V. Watkins
Chief Comnlissianer
Wm. M. Ilolt
-
A s s x i ate Commissioner