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“The Doctrine of Christian Discovery and Domination: How It Has Been Used by United,” an Outcome archive entry by Joseph J. Heath. The entry belongs to the jcrt collection and connects readers to scholarship, public history, and organizing around the Doctrine of Discovery, Christian domination, Indigenous sovereignty, law, religion, land, memory, and accountability.

In brief, it addresses Joseph J. Heath shows how U.S. courts use Christian Discovery to deny Haudenosaunee treaty and land rights, and calls for its repudiation in U.S. law.. For readers arriving from the main Doctrine of Discovery site, this post functions as a pointer rather than a replacement for the full Outcome record. The canonical page preserves the complete context, metadata, author information, citation links, media, and neighboring materials in the archive.

The source text highlights terms and contexts including This article examines how the doctrine of Christian discovery and domination continues to serve as the foundational legal justification used by United States courts to deny treaty rights and dismiss Indigenous land rights claims, with particular focus on Haudenosaunee nations. Centering the Supreme Court’s decision in City of Sherrill v. Oneida Indian Nation (2005), the article critiques the Court’s revival of colonial doctrine through a fabricated “equitable” defense mislabeled as laches. It traces Sherrill’s jurisprudential roots to Johnson v. M’Intosh (1823), where Chief Justice John Marshall embedded Christian European claims of domination into United States law as a mechanism for Indigenous dispossession. The. Read the canonical Outcome page for the complete entry.

Canonical link: https://outcome.doctrineofdiscovery.org/jcrt/issue2/heath/

SUGGESTED CITATION

Adam DJ Brett, "The Doctrine of Christian Discovery and Domination: How It Has Been Used by United States Courts to Deny Treaty Rights & Dismiss the Haudenosaunee Land Rights Cases," Doctrine of Discovery Project (16 April 2026), https://doctrineofdiscovery.org/blog/link/outcome/jcrt/issue2/heath/.

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