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Published in Legal Reference Services Quarterly, 29 (2010), pp. 133–148; doi: 10.1080/02703191003751230 Copyright © 2010 Taylor & Francis Group, LLC. Used by permission.


The Treaty of Fort Laramie with Sioux, etc., 1851 was an important transaction between a number of American Indian tribes and the federal government. However, because of administrative mishandling by the latter, there has been sustained but unwarranted confusion over whether the treaty was a valid one. Uncertainty led to the use of a brief note in the Statutes at Large, at 11 Stat. 749, instead of the treaty’s full text as the law of the land. The Statutes cue, however, has been misused frequently in the opinions of various jurisdictions, even to the point of deploying it to reference specific quotations from the full document—that is, to material certainly taken from an alternative source. This article investigates the most significant citation errors to 11 Stat. 749, and uses them to discuss improvements to applications of legal writing.