This article was published in Indian Affairs, Volume 195, Fall/Winter 2025 Journal. By: Kailash Muthukumar and Sky Ravenscroft Today, Native Nations and their citizens face unique challenges in safeguarding their cultural heritage from exploitation and appropriation. Native Peoples hold distinct traditions and cultural expressions that are both rich and deeply significant. However, existing U.S. copyright laws, rooted in Western notions of individual ownership and originality, fail to adequately protect these cultural expressions. The result is a persistent and damaging pattern of cultural appropriation, where sacred designs, symbols, and knowledge are commercialized without consent, diminishing Indigenous rights and eroding cultural identity. Examining the legal gaps that leave Indigenous heritage vulnerable to exploitation, this article explores the urgent need for reform that upholds Indigenous sovereignty and preserves diverse Native cultural heritage. |
Congress possesses the authority to enact laws on intellectual property issues, theoretically obligating lawmakers to protect Indigenous cultural heritage under the established “trust” or fiduciary relationship between the federal government and Native Nations. Nevertheless, current U.S. copyright law falls short in its ability to protect Indigenous cultural expressions. These limitations contribute to the erosion of Indigenous rights and identity through inadequate safeguards against cultural misappropriations, unwanted commodification of sacred cultural symbols, disregard of cultural meaning and significance, and perpetuated economic inequity.
Inadequate Copyright Safeguards for Indigenous Culture
Current U.S. copyright law offers only limited protection for Indigenous cultural expressions, which are often ineligible for copyright. The law generally applies to original, individually authored works, which conflicts with the nature of Indigenous heritage. Many Indigenous creations are collective works, intended to serve the entire Nation, and may lack a specific individual author. These works are culturally valuable, often originating from centuries-old
traditions; yet copyright law does not adequately recognize these qualities. As a result, many traditional symbols, designs, and patterns lack basic legal protections, exposing them to misuse and appropriation without recourse. For example, woven patterns or jewelry designs specific to certain Nations are frequently commercialized without regard for their cultural or historical significance, underscoring the flaws in copyright law’s narrow focus on “originality.”(1)
Cultural Appropriation Without Legal Recourse
Another significant gap in copyright law is the inability of Native Nations to prevent the appropriation of their cultural expressions. Non-Indigenous companies and individuals frequently take designs, symbols, and motifs with deep cultural significance and commercialize them for profit. This commodification often deprives Indigenous creators of economic benefits and diminishes Native sovereignty by stripping away control over their cultural expressions. Companies profit while Native Nations and Native artists receive nothing in return, losing out economically and culturally. For example, Indigenous patterns and iconography have been used extensively on clothing and merchandise without permission, transforming sacred cultural markers into commodities. This not only trivializes the heritage of Native Nations but also weakens their sovereignty by further entrenching economic inequity.(2)
Case Study: Navajo Nation v. Urban Outfitters. The Navajo Nation v. Urban Outfitters case highlights a significant legal conflict over cultural appropriation and trademark infringement. The Navajo Nation sued Urban Outfitters in 2012 for using its “Navajo” name and patterns on commercial products without permission, arguing this misappropriation violated its trademark and damaged its cultural heritage.(3) The commercial products in question included
clothing, underwear, and mini flasks commonly used for alcohol consumption featuring patterns considered by the Navajo Nation as representing cultural heritage.(4) In 2016, after years of litigation, the two parties reached a confidential settlement. As part of the agreement, Urban Outfitters acknowledged the validity of the Navajo Nation’s trademark and entered a licensing agreement and plans for future collaboration on authentic Native products.(5) This landmark case underscores the importance of protecting Indigenous intellectual property and fostering ethical business practices.
Limited Duration of Copyright Protection
Copyright protection is generally limited to the life of the creator plus 70 years, or 120 years for corporate works. However, many Indigenous cultural expressions are hundreds of years old and intended for indefinite preservation. Limiting protection to a finite period conflicts with Indigenous beliefs and cultural priorities, which hold that these expressions should remain safeguarded in perpetuity. Unlike Western art forms that may cycle in and out of popularity, Indigenous art and symbols carry ongoing relevance and meaning. As a result, finite protections leave these works vulnerable to exploitation once the copyright expires, disregarding Indigenous perspectives on the significance and sanctity of cultural heritage.(6)
Public Domain Vulnerability
If designs are in the public domain, anyone can reproduce Indigenous designs, styles, and motifs without permission, often stripping them of their original meanings. This opens the door to misuse that commodifies and erases Indigenous heritage, reducing cultural expressions to marketable goods. Because many Indigenous cultural expressions do not qualify for copyright, they may be used as public domain. This often means that Native national cultural patrimony can be freely accessed, modified, and repurposed by almost anyone for almost anything. This puts cultural traditions at risk of distortion, commercialization, and misrepresentation that can be viewed as offensive by Native Country. For example, the “Navajo flask” that was sold by Urban Outfitters could be seen as highly insensitive due to the deadly history that alcohol has played in Native communities. By disregarding the context in which Indigenous works were created, public domain laws expose them to misuse without any input, consent, or benefit from Native Nations.(7)
Case Study: The Complicated History of Pendleton Trade Blankets
Pendleton blankets, renowned for their vibrant patterns inspired by Native designs, have sparked controversy over cultural appropriation and ethical business practices. Critics argue that Pendleton Woolen Mills profits from sacred Indigenous symbols without adequately compensating or crediting the communities that originated them.(8) While the designs hold deep cultural and spiritual significance, Pendleton reduces them to decorative commodities, raising concerns about cultural exploitation and intellectual property rights. Additionally, the economic disparity between the company’s success and the financial struggles of many Native Nations underscores the inequities in how these designs are commercialized. Pendleton’s marketing practices, such as naming products after Indigenous themes, further highlight the tension between celebrating and commodifying Native heritage.(9)
Despite the criticism, Pendleton blankets hold a special place with many Native Peoples, often used as gifts, and symbols of cultural pride for more than a century (mostly because there was no Native owned company that could compete).(10) This dual role complicates the debate, as some see the blankets as tools for honoring heritage while others view them as products of exploitation. In recent years, Pendleton has sought to address these concerns by collaborating with Native artists and supporting cultural programs, though critics argue these efforts are insufficient to rectify decades of inequity.(11) The controversy reflects broader issues of cultural appropriation and economic justice, emphasizing the need for ethical partnerships and respect for the cultural origins of Indigenous-inspired designs.
Psychological, Cultural, and Economic Impact on Native Nations.
The impact of these legal gaps goes beyond economic harm, contributing to psychological and cultural harm and a continued erosion of sovereignty and self-determination – Native Nation rights protected by the U.S. Constitution, treaties, federal law and international law. The unauthorized commercialization of Indigenous cultural expressions often commodifies sacred symbols, depriving them of their inherent significance. The effects are both emotional and economic. While non-Indigenous companies profit from these expressions, Indigenous creators often struggle to receive fair compensation for their work. This economic disparity deepens existing inequalities and further entrenches colonial power dynamics. Additionally, the appropriation of Indigenous cultural heritage disrupts the sovereignty of Native Nations, depriving them of control over expressions that have defined their identity for generations.(12)
Case Study: Copyright Struggle of the Lakota Language
The Lakota Language Consortium (LLC), a group focused on preserving the Lakota language through written materials like dictionaries and textbooks, faced backlash from the Standing Rock Sioux Tribe and was banned from the reservation.(13) While LLC’s work has helped standardize and preserve the language, its founders, who are non-Native, copyrighted these materials, making them costly for Native citizens to use their own language. This sparked outrage, as many Lakota believe their language and its learning tools should remain communal and free.(14) Activists call this a fight for “data sovereignty,” arguing that language ownership should rest with their Native Nation. Although LLC justifies costs as necessary for publishing, the controversy highlights tensions between U.S. copyright law and Indigenous cultural preservation. Some Native Peoples advocate for collaboration to balance linguistic preservation with Native control.(15)
The Need for Policy Reform
To address these harms, reforms are urgently needed to safeguard Indigenous sovereignty, self-determination and cultural heritage. Indigenous advocates are working to advance policy changes both at the World Intellectual Property Organization (WIPO) and within the U.S. to establish permanent protections for Indigenous cultural expressions, limit exploitative fair use practices, and recognize collective ownership rights. Several specific policy changes could address these needs.
First, establishing perpetual protection for Indigenous cultural expressions is essential. Unlike typical copyright works, which enter the public domain after a set period, Indigenous cultural expressions must remain protected indefinitely to prevent exploitation. This change would require creating national legislation that recognizes Native Nation customs and laws protecting intangible and tangible cultural heritage and excludes Native cultural heritage from U.S. copyright law, recognizing the distinct and lasting value of Indigenous cultural works.
Second, U.S. law must recognize Native Nation national patrimony and communal authorship. By acknowledging the collective nature of Indigenous creations, lawmakers could empower Native Nations to claim collective ownership of their cultural expressions, granting them the legal means to prevent unauthorized use. This communal authorship model would reflect the cultural realities of Indigenous creation, where art and tradition are shared, rather than individually owned, expressions. In addition, this is in line with other laws protecting Native cultural heritage such as the Native American Graves Protection and Repatriation Act.
Third, preventing the application of fair use to Indigenous cultural expressions is critical. Currently, the fair use doctrine allows courts to overlook the cultural importance of Indigenous works, permitting unauthorized uses in certain cases. A reform that requires courts to consider the impact of appropriation on Indigenous communities, especially regarding culturally significant symbols, could prevent harmful uses of fair use exemptions.
Conclusion: Taking Action to Preserve Indigenous Heritage
The gaps in current intellectual property law fail to honor the cultural rights and sovereignty of Native Nations, leaving their cultural heritage vulnerable to misuse and exploitation. The U.S. government must act to reform copyright law, ensuring that Native Nations have the tools needed to protect their cultural expressions. This change would not only fulfill the government’s fiduciary responsibility to Native Nations, but also promote justice by preserving diverse Native cultural heritage for future generations.
Native Nations deserve to retain control over their cultural heritage, safeguarding their traditions and determining how their expressions are shared with the world. Strengthening protections for Indigenous intellectual property will not only honor their sovereignty and self-determination but also provide a vital pathway toward cultural preservation for all Indigenous Peoples in an increasingly globalized world.
Sources:
1. Rebecca A. Tsosie, “Reclaiming Native Stories: An Essay on Cultural Appropriation and Cultural Rights,” SSRN Scholarly Paper (Rochester, NY: Social Science Research Network, 2002), papers.ssrn.com/abstract=1401522; Emilie Smith Rohde, “AQuestionableCategorization—Trademark’s Struggle to Protect Tribal Cultural Property,”MarquetteIntellectual Property & Innovation Law Review 28, no. 1 (2024): 33–58,
https://scholarship.law.marquette.edu/ipilr/vol28/iss1/5/.
2. Tyler Heneghan, “The Colonization of Native American Trademarks and Designs: The Past, Present, and (Potentially Decolonized) Future,” Center for Art Law, 2021, itsartlaw.org/2021/06/22/the-colonization-of-nativeamerican-trademarks-and-designs-the-past-present-and-potentiallydecolonized-future/; see also Emilie Smith Rohde, note 1.
3. National Indian Law Library, “Navajo Nation v. Urban Outfitters, Inc, Indian Law Bulletins,” 2016, https://nill.narf.org/bulletins/federal/documents/navajo_v_urban_outfitters_may2016.html.
4. Carey Dunne, “Urban Outfitters Wins Partial Victory Over Navajo Nation in Trademark Dispute,” Hyperallergic, 2016, hyperallergic.com/300457/urbanoutfitters-wins-partial-victory-over-navajo-nation-in-trademark-dispute/.
5. Nicky Woolf, “Urban Outfitters Settles with Navajo Nation after Illegally Using Tribe’s Name,” The Guardian, November 19, 2016, sec. US news, theguardian.com/us-news/2016/nov/18/urban-outfitters-navajo-nationsettlement.
6. Trevor Reed, “Fair Use as Cultural Appropriation,” California Law Review 109, no. 4 (2021): 1373, lawcat.berkeley.edu/record/1211445?v=pdf.
7. Barbara Pozzo, “Fashion between Inspiration and Appropriation,” Laws 9, no. 1 (March 2020): 5, doi.org/10.3390/laws9010005.
8. Adrienne K., “Let’s Talk About Pendleton,” Native Appropriations, 2011, nativeappropriations.com/2011/02/lets-talk-about-pendleton.
9. Conor Knighton, “Pendleton Blankets: A Thread to the Past - CBS News,” 2023, cbsnews.com/news/pendleton-blankets-a-thread-to-the-past/.
10. PowWows.com, “Pendleton Blankets and Their ‘Native American’ Inspiration,” PowWows.com, 2023, powwows.com/pendleton-blanketsand-their-native-american-inspiration.
11. Knighton, see note 9.
12. Pozzo, see note 7; and Tyler Heneghan, see note 2.
13. Crystal Broughan, “The Copyright Struggle Over Lakota Written Language,” Marks Gray, 2022, marksgray.com/intellectual-property/the-copyrightstruggle-over-lakota-written-language.
14. B.A. Parker, Christina Cala, and Wilhelm Meya, “In Lakota Nation, People Are Asking: Who Does a Language Belong to?: Code Switch,” NPR, 2024, npr.org/2024/03/27/1197956092/in-lakota-nation-people-are-asking-whodoes-a-language-belong-to.
15. Crystal Broughan, see note 14.
Inadequate Copyright Safeguards for Indigenous Culture
Current U.S. copyright law offers only limited protection for Indigenous cultural expressions, which are often ineligible for copyright. The law generally applies to original, individually authored works, which conflicts with the nature of Indigenous heritage. Many Indigenous creations are collective works, intended to serve the entire Nation, and may lack a specific individual author. These works are culturally valuable, often originating from centuries-old
traditions; yet copyright law does not adequately recognize these qualities. As a result, many traditional symbols, designs, and patterns lack basic legal protections, exposing them to misuse and appropriation without recourse. For example, woven patterns or jewelry designs specific to certain Nations are frequently commercialized without regard for their cultural or historical significance, underscoring the flaws in copyright law’s narrow focus on “originality.”(1)
Cultural Appropriation Without Legal Recourse
Another significant gap in copyright law is the inability of Native Nations to prevent the appropriation of their cultural expressions. Non-Indigenous companies and individuals frequently take designs, symbols, and motifs with deep cultural significance and commercialize them for profit. This commodification often deprives Indigenous creators of economic benefits and diminishes Native sovereignty by stripping away control over their cultural expressions. Companies profit while Native Nations and Native artists receive nothing in return, losing out economically and culturally. For example, Indigenous patterns and iconography have been used extensively on clothing and merchandise without permission, transforming sacred cultural markers into commodities. This not only trivializes the heritage of Native Nations but also weakens their sovereignty by further entrenching economic inequity.(2)
Case Study: Navajo Nation v. Urban Outfitters. The Navajo Nation v. Urban Outfitters case highlights a significant legal conflict over cultural appropriation and trademark infringement. The Navajo Nation sued Urban Outfitters in 2012 for using its “Navajo” name and patterns on commercial products without permission, arguing this misappropriation violated its trademark and damaged its cultural heritage.(3) The commercial products in question included
clothing, underwear, and mini flasks commonly used for alcohol consumption featuring patterns considered by the Navajo Nation as representing cultural heritage.(4) In 2016, after years of litigation, the two parties reached a confidential settlement. As part of the agreement, Urban Outfitters acknowledged the validity of the Navajo Nation’s trademark and entered a licensing agreement and plans for future collaboration on authentic Native products.(5) This landmark case underscores the importance of protecting Indigenous intellectual property and fostering ethical business practices.
Limited Duration of Copyright Protection
Copyright protection is generally limited to the life of the creator plus 70 years, or 120 years for corporate works. However, many Indigenous cultural expressions are hundreds of years old and intended for indefinite preservation. Limiting protection to a finite period conflicts with Indigenous beliefs and cultural priorities, which hold that these expressions should remain safeguarded in perpetuity. Unlike Western art forms that may cycle in and out of popularity, Indigenous art and symbols carry ongoing relevance and meaning. As a result, finite protections leave these works vulnerable to exploitation once the copyright expires, disregarding Indigenous perspectives on the significance and sanctity of cultural heritage.(6)
Public Domain Vulnerability
If designs are in the public domain, anyone can reproduce Indigenous designs, styles, and motifs without permission, often stripping them of their original meanings. This opens the door to misuse that commodifies and erases Indigenous heritage, reducing cultural expressions to marketable goods. Because many Indigenous cultural expressions do not qualify for copyright, they may be used as public domain. This often means that Native national cultural patrimony can be freely accessed, modified, and repurposed by almost anyone for almost anything. This puts cultural traditions at risk of distortion, commercialization, and misrepresentation that can be viewed as offensive by Native Country. For example, the “Navajo flask” that was sold by Urban Outfitters could be seen as highly insensitive due to the deadly history that alcohol has played in Native communities. By disregarding the context in which Indigenous works were created, public domain laws expose them to misuse without any input, consent, or benefit from Native Nations.(7)
Case Study: The Complicated History of Pendleton Trade Blankets
Pendleton blankets, renowned for their vibrant patterns inspired by Native designs, have sparked controversy over cultural appropriation and ethical business practices. Critics argue that Pendleton Woolen Mills profits from sacred Indigenous symbols without adequately compensating or crediting the communities that originated them.(8) While the designs hold deep cultural and spiritual significance, Pendleton reduces them to decorative commodities, raising concerns about cultural exploitation and intellectual property rights. Additionally, the economic disparity between the company’s success and the financial struggles of many Native Nations underscores the inequities in how these designs are commercialized. Pendleton’s marketing practices, such as naming products after Indigenous themes, further highlight the tension between celebrating and commodifying Native heritage.(9)
Despite the criticism, Pendleton blankets hold a special place with many Native Peoples, often used as gifts, and symbols of cultural pride for more than a century (mostly because there was no Native owned company that could compete).(10) This dual role complicates the debate, as some see the blankets as tools for honoring heritage while others view them as products of exploitation. In recent years, Pendleton has sought to address these concerns by collaborating with Native artists and supporting cultural programs, though critics argue these efforts are insufficient to rectify decades of inequity.(11) The controversy reflects broader issues of cultural appropriation and economic justice, emphasizing the need for ethical partnerships and respect for the cultural origins of Indigenous-inspired designs.
Psychological, Cultural, and Economic Impact on Native Nations.
The impact of these legal gaps goes beyond economic harm, contributing to psychological and cultural harm and a continued erosion of sovereignty and self-determination – Native Nation rights protected by the U.S. Constitution, treaties, federal law and international law. The unauthorized commercialization of Indigenous cultural expressions often commodifies sacred symbols, depriving them of their inherent significance. The effects are both emotional and economic. While non-Indigenous companies profit from these expressions, Indigenous creators often struggle to receive fair compensation for their work. This economic disparity deepens existing inequalities and further entrenches colonial power dynamics. Additionally, the appropriation of Indigenous cultural heritage disrupts the sovereignty of Native Nations, depriving them of control over expressions that have defined their identity for generations.(12)
Case Study: Copyright Struggle of the Lakota Language
The Lakota Language Consortium (LLC), a group focused on preserving the Lakota language through written materials like dictionaries and textbooks, faced backlash from the Standing Rock Sioux Tribe and was banned from the reservation.(13) While LLC’s work has helped standardize and preserve the language, its founders, who are non-Native, copyrighted these materials, making them costly for Native citizens to use their own language. This sparked outrage, as many Lakota believe their language and its learning tools should remain communal and free.(14) Activists call this a fight for “data sovereignty,” arguing that language ownership should rest with their Native Nation. Although LLC justifies costs as necessary for publishing, the controversy highlights tensions between U.S. copyright law and Indigenous cultural preservation. Some Native Peoples advocate for collaboration to balance linguistic preservation with Native control.(15)
The Need for Policy Reform
To address these harms, reforms are urgently needed to safeguard Indigenous sovereignty, self-determination and cultural heritage. Indigenous advocates are working to advance policy changes both at the World Intellectual Property Organization (WIPO) and within the U.S. to establish permanent protections for Indigenous cultural expressions, limit exploitative fair use practices, and recognize collective ownership rights. Several specific policy changes could address these needs.
First, establishing perpetual protection for Indigenous cultural expressions is essential. Unlike typical copyright works, which enter the public domain after a set period, Indigenous cultural expressions must remain protected indefinitely to prevent exploitation. This change would require creating national legislation that recognizes Native Nation customs and laws protecting intangible and tangible cultural heritage and excludes Native cultural heritage from U.S. copyright law, recognizing the distinct and lasting value of Indigenous cultural works.
Second, U.S. law must recognize Native Nation national patrimony and communal authorship. By acknowledging the collective nature of Indigenous creations, lawmakers could empower Native Nations to claim collective ownership of their cultural expressions, granting them the legal means to prevent unauthorized use. This communal authorship model would reflect the cultural realities of Indigenous creation, where art and tradition are shared, rather than individually owned, expressions. In addition, this is in line with other laws protecting Native cultural heritage such as the Native American Graves Protection and Repatriation Act.
Third, preventing the application of fair use to Indigenous cultural expressions is critical. Currently, the fair use doctrine allows courts to overlook the cultural importance of Indigenous works, permitting unauthorized uses in certain cases. A reform that requires courts to consider the impact of appropriation on Indigenous communities, especially regarding culturally significant symbols, could prevent harmful uses of fair use exemptions.
Conclusion: Taking Action to Preserve Indigenous Heritage
The gaps in current intellectual property law fail to honor the cultural rights and sovereignty of Native Nations, leaving their cultural heritage vulnerable to misuse and exploitation. The U.S. government must act to reform copyright law, ensuring that Native Nations have the tools needed to protect their cultural expressions. This change would not only fulfill the government’s fiduciary responsibility to Native Nations, but also promote justice by preserving diverse Native cultural heritage for future generations.
Native Nations deserve to retain control over their cultural heritage, safeguarding their traditions and determining how their expressions are shared with the world. Strengthening protections for Indigenous intellectual property will not only honor their sovereignty and self-determination but also provide a vital pathway toward cultural preservation for all Indigenous Peoples in an increasingly globalized world.
Sources:
1. Rebecca A. Tsosie, “Reclaiming Native Stories: An Essay on Cultural Appropriation and Cultural Rights,” SSRN Scholarly Paper (Rochester, NY: Social Science Research Network, 2002), papers.ssrn.com/abstract=1401522; Emilie Smith Rohde, “AQuestionableCategorization—Trademark’s Struggle to Protect Tribal Cultural Property,”MarquetteIntellectual Property & Innovation Law Review 28, no. 1 (2024): 33–58,
https://scholarship.law.marquette.edu/ipilr/vol28/iss1/5/.
2. Tyler Heneghan, “The Colonization of Native American Trademarks and Designs: The Past, Present, and (Potentially Decolonized) Future,” Center for Art Law, 2021, itsartlaw.org/2021/06/22/the-colonization-of-nativeamerican-trademarks-and-designs-the-past-present-and-potentiallydecolonized-future/; see also Emilie Smith Rohde, note 1.
3. National Indian Law Library, “Navajo Nation v. Urban Outfitters, Inc, Indian Law Bulletins,” 2016, https://nill.narf.org/bulletins/federal/documents/navajo_v_urban_outfitters_may2016.html.
4. Carey Dunne, “Urban Outfitters Wins Partial Victory Over Navajo Nation in Trademark Dispute,” Hyperallergic, 2016, hyperallergic.com/300457/urbanoutfitters-wins-partial-victory-over-navajo-nation-in-trademark-dispute/.
5. Nicky Woolf, “Urban Outfitters Settles with Navajo Nation after Illegally Using Tribe’s Name,” The Guardian, November 19, 2016, sec. US news, theguardian.com/us-news/2016/nov/18/urban-outfitters-navajo-nationsettlement.
6. Trevor Reed, “Fair Use as Cultural Appropriation,” California Law Review 109, no. 4 (2021): 1373, lawcat.berkeley.edu/record/1211445?v=pdf.
7. Barbara Pozzo, “Fashion between Inspiration and Appropriation,” Laws 9, no. 1 (March 2020): 5, doi.org/10.3390/laws9010005.
8. Adrienne K., “Let’s Talk About Pendleton,” Native Appropriations, 2011, nativeappropriations.com/2011/02/lets-talk-about-pendleton.
9. Conor Knighton, “Pendleton Blankets: A Thread to the Past - CBS News,” 2023, cbsnews.com/news/pendleton-blankets-a-thread-to-the-past/.
10. PowWows.com, “Pendleton Blankets and Their ‘Native American’ Inspiration,” PowWows.com, 2023, powwows.com/pendleton-blanketsand-their-native-american-inspiration.
11. Knighton, see note 9.
12. Pozzo, see note 7; and Tyler Heneghan, see note 2.
13. Crystal Broughan, “The Copyright Struggle Over Lakota Written Language,” Marks Gray, 2022, marksgray.com/intellectual-property/the-copyrightstruggle-over-lakota-written-language.
14. B.A. Parker, Christina Cala, and Wilhelm Meya, “In Lakota Nation, People Are Asking: Who Does a Language Belong to?: Code Switch,” NPR, 2024, npr.org/2024/03/27/1197956092/in-lakota-nation-people-are-asking-whodoes-a-language-belong-to.
15. Crystal Broughan, see note 14.