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This study explores the complex issues surrounding comparative genocide studies and how Native American history relates to this field. Historical contexts for Native American historiography, particularly the scholarship of Vine Deloria, Jr., are examined. In addition, the manifestation of some problematic trends in the field is detailed through the mordant debate between scholars of native America and the Jewish Holocaust. Arguments over Holocaust uniqueness and how the depopulation of Native America should be classified typifies how certain aspects of comparative genocide studies have a propensity for subjectively motivated and biased methodology. Finally, a case study using the historiography of the 1864 Sand Creek Massacre of Cheyennes and Araphahoes in southeastern Colorado by the Colorado Militia helps illustrate the difficulties in producing objective research on such morally-charged historical events. By examining these issues, the historiography of Native American genocide studies are both chronicled and critiqued.