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This article explores various issues germane to the field of the history of the North American West and the struggle to integrate these issues into the broader field of genocide studies. The primary historiographic example of the 1864 Sand Creek Massacre of Cheyennes and Araphahos in southeastern Colorado by the Colorado Militia illustrates the difficulties of producing objective research on such morally charged historical events. Specific attention is dedicated to understanding the potential value of integrating Native American history into the broader field of genocide studies and to explaining why comparative scholarship has yet to be undertaken in any substantial way. Building on this foundation, the article reveals the challenges facing genocide scholars in integrating the history of the North American West into the field of genocide studies, particularly in a comparative sense.