In my book, I mention this 1823 Supreme Court decision that said that Indigenous people only had occupancy rights to our land — not full title — so settlers who “discovered” our land could legally take it. That ruling was based on the “doctrine of discovery.” The Chief Justice in that case, John Marshall, cited a fifteenth-century papal bull called the “Doctrine of Christian Discovery” that was used to legally justify Portugal’s claims to land in West Africa. The reasoning was that, just like non-Christians in West Africa were considered “savages” who couldn’t own their own land, we couldn’t have full title to our land because we’re not full humans who exist at the level of civilization — a doctrine decided and standardized, of course, by the colonizing nation.