Dartmouth Conducts Review of NAGPRA Compliance

News subtitle

The work will return ancestral remains and atone for the harm caused.

Dartmouth Hall
(Photo by Chris Johnson)

As part of an ongoing effort to ensure that Dartmouth is in compliance and actively pursuing repatriation under the Native American Graves Protection and Repatriation Act, known as NAGPRA, a visiting team of forensic anthropologists and archaeologists is working with Dartmouth to re-inventory human skeletal remains in Dartmouth’s possession. The visit comes after an ongoing internal review of the institution’s osteology collections unexpectedly discovered the inclusion of previously unreported Native American ancestral remains.

NAGPRA provides a legal framework through which federally funded museums and institutions consult with federally recognized Native American tribes and Native Hawaiian organizations to provide for the repatriation of human remains as well as funerary, sacred, and communally owned items. Dartmouth had performed an earlier inventory in 1995 and has undertaken several repatriations of Native remains since then. This recent discovery is believed to have been the result of recording errors before 1995, and in many cases dating back to the origin of the collections. NAGPRA provides a process for discoveries of previously unreported current holdings, which Dartmouth has implemented.

President Philip J. Hanlon ’77 apologized for Dartmouth’s wrongful possession of Native American ancestral remains and the resulting trauma to Native American and Indigenous members of the Dartmouth community and to greater Indian Country.

“I am deeply saddened by what we’ve found on our campus,” says President Hanlon. “On behalf of Dartmouth, I sincerely apologize to our entire community. This is an extremely painful discovery, especially for Native American and Indigenous students and alumni, and for the faculty and staff who believed in good faith that they were not teaching with ancestral remains in their classrooms and labs.”

“We know this finding comes in the context of overwhelming grief for Native and Indigenous people as they struggle with the discovery of ancestral remains at institutions throughout the country,” he says. “In great sympathy with all of the pain that Indian Country is enduring, we at Dartmouth pledge to take careful and meaningful action to address our situation and consult with the communities most directly impacted. Dartmouth is dedicated to righting these heartbreaking wrongs.”

External review follows recent internal audit

Passed in 1990, NAGPRA mandates that institutions receiving federal funds must compile an inventory of Native American remains and associated funerary objects as well as a summary of other cultural items. The law required inventories of ancestral remains and associated funerary objects be completed in consultation with tribal nations and Native Hawaiian organizations and submitted within five years of the passage of NAGPRA. Dartmouth’s original inventory was completed by the Hood Museum of Art in 1995.

The external review follows a recent internal audit conducted by faculty and staff from the Department of Anthropology and the museum. The audit uncovered a series of cataloguing and physical inventory errors, which revealed some human remains previously believed to be non-Native—including some formerly included in teaching collections—are in fact Native American.

“Dartmouth takes NAGPRA seriously and is deeply committed to a positive and respectful relationship with tribal nations and Native Hawaiians. We will be transparent as we work to repair the harm this has caused. It’s not merely a matter of following the letter of the law, but of doing what’s right,” Hanlon says.

In addition to the external review, Dartmouth is working to communicate with all current students, faculty, and alumni who may have unwittingly handled the ancestral remains or taken classes in buildings where the remains were previously housed.

“In my Navajo culture, it is taboo to even speak about this topic,” says Hilary Tompkins ’90, a Dartmouth trustee, member of the Navajo Nation, and a leading attorney in natural resources, environmental, and Indian law. “What I can say is that I appreciate Dartmouth’s acceptance and ownership of its past and harmful history, and its efforts today to do what is right and handle this situation in a respectful and open manner.”

Exploring how to move forward; changes underway

Museum and anthropology staff have undertaken measures to ensure the safe storage of the remains, including those that have not been identified as Native American ancestors, and moved them to a secure facility located off campus, says Jami Powell, the Hood’s associate director of curatorial affairs and curator of Indigenous art. Powell, a citizen of the Osage Nation, was hired in 2018 as the Hood’s first associate curator of Native American art.

Bruce Duthu ’80, the Samson Occom Professor and chair of the Department of Native American and Indigenous Studies, says, “We’re working with President Hanlon and others in leadership to schedule appropriate actions soon, including holding a cleansing ceremony in the locations where the ancestral remains had been housed and a blessing ceremony of the off-campus site where remains are being kept while consultation and repatriation planning take place.” 

Duthu and others will take part in two Zoom sessions for Native and Indigenous alumni—today, March 28, at 5 p.m. and tomorrow, March 29, at 7:30 p.m. On Thursday, March 30, Duthu and Jeremy DeSilva, professor and chair of the Department of Anthropology, will hold a listening session for students who have majored or minored in anthropology or Native American and Indigenous studies. That in-person gathering will be held at 5 p.m. at South House.

Also, in recent days senior leaders have consulted with Dartmouth’s Native American Visiting Committee, whose members advise the president.

Provost David Kotz ’86 will convene a task force to address institution-wide issues beyond NAGPRA, including the handling and repatriation of ancestral remains determined to be non-Native American and those from other countries. A project manager will be hired to work with anthropology, the museum, and the Division of Institutional Diversity and Equity on NAGPRA issues and on other matters the findings have raised.

The findings have resulted in the reevaluation of the anthropology teaching collection and have led Dartmouth to plan to build an ethically sourced collection that complies with legal standards to be used in any future osteology instruction—the study of bones and skeletal systems. The anthropology department will not offer an osteology course for the foreseeable future.

“The faculty want to be 100% confident that any materials used for teaching have been ethically obtained before they list such courses again,” says Kotz.

A brief history of Dartmouth and NAGPRA

To understand how skeletal remains could have been miscatalogued—and how the mistake was identified—requires understanding how such remains came to Dartmouth in the first place, says Kotz.

“The history of human skeletal acquisitions is ugly,” he says. As North American archaeology was established as a discipline, researchers excavated Native American burial mounds, and some of those cultural artifacts became part of the Dartmouth collection.

“Alumni would travel the world and donate things they collected. The osteological collection was accumulated over the course of more than 200 years in this piecemeal fashion, and documentation was not always present or well-established,” Kotz explains.

Until the 1980s, art, artifacts, and ancestral remains at Dartmouth were maintained by what was the Dartmouth College Museum and stored in various academic departments across campus, often with little or no documentation recording their movements. Most of these collections were consolidated and moved to the Hood Museum of Art when it opened in 1985.

After NAGPRA became law in 1990, the museum led the required institution-wide inventory of Dartmouth’s Native American holdings, completed in 1995. Since then, the museum has facilitated four repatriations of ancestral remains, one with an associated funerary object, to Indian tribes and Native Hawaiian organizations.

In 2018, the anthropology department received a bequest of Inuit ancestral remains from the estate of a former professor and proactively organized their repatriation to Nunavik, Canada. As these ancestral remains were originally removed from Canada and not the United States, they did not fall under the purview of NAGPRA. At that time, however, no one in the department suspected that other bones used in teaching were Native American.

Other departments and schools on campus, including anthropology and the Geisel School of Medicine, have long maintained osteological collections, used in the teaching of anatomy and forensics. From the mid-1990s on, these departments believed that their collections had been thoroughly reviewed and that what remained did not fall under the purview of NAGPRA.

The Geisel osteological teaching collection has no remains that are archaeological in origin and the medical school has been teaching using mostly bones made of plastic, which it will continue to do until its osteological collection has been fully audited by the visiting team.

Updating the Hood Museum’s NAGPRA inventory

Powell has extensive experience with NAGPRA and specifically the consultation and repatriation of Native American remains and associated funerary objects from her past work at the Denver Museum of Nature and Science. Soon after she was hired five years ago, she took on the role of Dartmouth’s NAGPRA officer and began to urge Dartmouth to find ways to proactively work toward the repatriation of the Native American ancestral remains it possessed.

“When I first came to Dartmouth, I asked about the number of remains in the collection, where they were from, what we knew about them, and if there was a desire to approach the repatriation process differently,” she says. “I planned to work on the repatriation of those ancestors more proactively.”

To do that, the museum collection needed to be re-inventoried, ideally by an independent physical anthropologist.

“From my experience at other institutions, I knew that the initial inventories done in the 1990s, when NAGPRA was first passed, were often rushed by necessity and conducted by staff who had numerous other responsibilities in terms of collections management and care. People were learning as they went, doing the best they could,” she says. “With that often came mistakes. So, before we started addressing the remains in Dartmouth’s collections, I wanted to make sure that we had a completely accurate inventory.”

The new inventory was initially delayed because of the museum’s renovation project, which was completed in 2019, then delayed further by restrictions of visitors during the COVID-19 pandemic. In the meantime, the museum and Dartmouth Library received a three-year grant from the Andrew W. Mellon Foundation to fund collaboration and research regarding Dartmouth’s Native American and Indigenous Arctic collections.

The grant created a temporary position for a cultural heritage and Indigenous knowledge fellow, who was tasked with facilitating the review of Dartmouth’s NAGPRA files in preparation for the re-inventory. The connection with the library was crucial, Powell says, because the archives at Rauner Special Collections Library hold the papers of many of the donors to the museum’s Native American collection—papers that can contain important clues to the provenance of specific objects, or in this case, ancestral remains and associated funerary objects.

In early 2021, the initial re-inventory was completed internally with the assistance of anthropology faculty. As a result of this initial re-inventory and research, the provost’s office in 2022 provided funding for the museum to hire Dartmouth’s first full-time employee dedicated to NAGPRA. Emily Andrews ’22, who had previously worked as Powell’s intern and as a NAGPRA intern at the Sam Noble Oklahoma Museum of Natural History, began as the NAGPRA research assistant in July 2022 and continued tracking down provenance clues and working with Powell and other museum staff to complete the updated inventory.

Reviewing the Department of Anthropology collections

As the museum was preparing its re-inventory, similar work was beginning in anthropology, which was moving its osteological teaching collection to a new teaching space within Silsby Hall in summer 2021.

At the time, the treatment of ancestral remains at other institutions was receiving media attention. These reports prompted the anthropology department to take a closer look at its own collection, which includes professionally prepared bones purchased from biological supply companies; bones from local, donated cadavers formerly used by medical students; and a small set of miscellaneous material from the Smithsonian or donated by alumni, with no known provenance.

“Our collection is small compared to others, but it’s big enough that it requires careful curation, and no single person had been in charge of that,” Kotz says. “The department saw the move as an opportunity to review and organize its holdings. They wanted to make sure every item had a catalogue number that could be matched back to a department-level spreadsheet.”

During the move, certain bones were flagged as having ambiguous labeling and appearance, including materials that looked archaeological—that is, showing traces of having been in the ground, such as stains or root impressions. Importantly, some of these fragments had been marked with accession numbers—numbers assigned when items are added to a collection—that did not conform to the anthropology department’s internal cataloging system. Some of these materials were separated from the teaching collection, and the reviewers recorded the nonconforming numbers in their spreadsheet.

Uncovering cataloging discrepancies

In November 2022, the anthropology department shared its spreadsheet with the museum and Andrews at once raised a red flag. The accession numbers that were unfamiliar to the department turned out to be familiar to the museum staff. In fact, the numbers were earlier Dartmouth College Museum-assigned accession numbers and indicated that many of the marked bones were Native American ancestral remains.

While the department had the ancestral remains, the museum had the documentation of what the remains actually were. To date, no record of how or when these remains physically came to the anthropology department has been found in the museum, the department, or Rauner.

With the help of the museum, the department began a systematic examination of every bone in its collection, searching for any nondepartmental numbers. The team identified fragmentary remains that corresponded with previously repatriated ancestral remains as well as known unrepatriated ancestors already in museum storage. The skeletal remains of 15 individuals identified as Native American, including five listed as missing or withdrawn from the museum collections and at least 10 marked with Smithsonian numbers and no other corresponding records, were also identified during this process.

Approximately 100 bones with no accession numbers were tagged as potentially problematic, based on appearance. Museum documentation also helped identify a small number of remains as originating internationally. Anthropology records show that some of the bones were used in human osteology teaching labs as recently as fall 2022.

Making things right

Work to identify and repatriate the ancestral remains continues. The external reviewers are helping to confirm the number of individuals represented within the entire holdings of Native American ancestral remains in Dartmouth’s possession, and, when necessary, to rearticulate skeletons that had been separated or damaged. They are also working to determine the cultural affiliation and other identifying factors, including the age and sex, of individual remains where possible.

Museum staff will continue to work with anthropology as well as staff at Rauner to find any and all associated records. This information will be utilized in consultation with tribal nations and Native Hawaiian organizations to complete the updated inventory and publish notices of inventory completion in the Federal Register, as required by NAGPRA. The museum has notified the National NAGPRA Program and will begin actively consulting with tribal nations and Native Hawaiian organizations as soon as the external review is complete. 

“We want to do everything possible to support tribal nations and Native Hawaiian organizations in the successful repatriation of these individuals whom we currently have in our custody and care,” Powell says. “In addition to repatriation, Dartmouth is thinking about the restorative work it can do for Indian Country and these tribal nations moving forward.”

Tribal and Native Hawaiian representatives who wish to consult with Dartmouth can write to hood.nagpra@dartmouth.edu.

The provostial task force will ensure that Dartmouth is meeting all of its obligations under NAGPRA. It will inventory all human remains affiliated with Dartmouth, with further detail on the composition of the task force to be announced soon. The group will recommend policies and procedures aimed at ensuring all remains are properly catalogued and maintained, and that records can be more easily accessed and shared throughout the institution.

“Dartmouth is more than 250 years old and recently celebrated the 50th anniversary of former Dartmouth President John Kemeny’s recommitment to Native Americans,” says Hanlon. “That milestone is a poignant reminder of the importance of taking responsibility for our past as we create a way forward.”

Dartmouth community members who have questions can write to nagpra.inquiry@dartmouth.edu.

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