14 Am. Indian L. Rev. 301 (1988-1989)
Cry, Sacred Ground: Big Mountain, U.S.A.

handle is hein.journals/aind14 and id is 307 raw text is: CRY, SACRED GROUND:
Anita Parlow*
Relocation is a word that does not exist in the Navajo
language. To be relocated is to disappear and never to be seen
Pauline Whitesinger
On Dec. 22, 1974, Congress enacted the Navajo-Hopi Indian
Relocation Act' to provide a final solution to a land dispute
between the Navajo and Hopi tribal governments that a federal
court called the largest title problem in the West.2 The Reloca-
tion Act partitioned into two equal parts 1.8 million acres of
land formerly held in common by both tribes and compelled reset-
tlement of eleven thousand Navajos and ten Hopis who lived on
the wrong side of the partitioning fence.3 The massive rangelands
* M.A., 1974, Goddard College, Vermont; J.D., 1980, Antioch School of Law.
Parlow has authored two books on Indian land-related issues: A Song for Sacred
Mountain (Pine Ridge, S.D.: Oglala Lakota Legal Rights Fund, 1983) and Cry, Sacred
Ground (Washington: Christic Institute, 1988). She has also written numerous articles,
and produced radio documentary programs for National Public Radio on the subject of
Indian land. She is executive producer of an eight-part radio documentary series, Bearing
Witness: Human Rights in the Americas, an independent series produced in cooperation
with WGBH Radio (Boston's National Public Radio affiliate), the Fund for Free Expres-
sion (the parent organization of Americas Watch), and the Conflict Clinic, Inc., affiliated
with George Mason University. This article was first published in the Eaford International
Review of Racial Discrimination, Without Prejudice (Spring, 1988).
1. Pub. L. No. 93-531, 88 Stat. 1712 (1974); Pub. L. No. 96-305, 94 Stat. 929 (codified
as amended in 25 U.S.C. § 640(d) to 640(d)(28) (1982)).
2. Healing v. Jones (II), 210 F. Supp. 125, 129 (D. Ariz. 1962), cert. denied, 373
U.S. 758 (1963). Rather than finally settling the land dispute, the court's decision has
served to intensify the controversy, generate further litigation, and has given rise to conti-
nuing efforts by an international support coalition to reverse the human rights abuses
caused by the Relocation Act that provided for the partition and explusion solution.
Many traditional Hopi and Navajo people support the view that the Navajo-Hopi
land dispute is a misnomer, diverting attention from the variety of interests involved
in the land dispute - interests which have the effect of destroying the foundation of
traditional life within the formerly jointly held Holy Lands. See Goodman & Thompson,
The Hopi-Navajo Land Dispute, 3 Am. INDL AN L. Rav. 397 (1975); Tehan, Of Indians,
Land and the Federal Government: The Navajo-Hopi Land Dispute, 2 Aaiz. ST. L.J.
173 (1976); Whitson, A Policy Review of the Federal Government's Relocation of Navajo
Indians Under P.L. 93-531 and Pub. L. 96-306, 27 Amxz. L. Rav. 371 (1985).
3. The precise number of relocatees has always been a matter of controversy, with
estimates ranging from approximately 3,500 to 15,000. However, the Relocation Act has
resulted in the largest forced relocation of a racial group since the internment of Japanese-
Americans during World War II under Exec. Order No. 9066, 3 C.F.R. 1092 (1942).

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