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Achieving Equal Educational Opportunities for Native American Youth: Lessons from Communities Working for Change

by Mae Ackerman-Brimberg


This article is the first in a two-part series.

“Public schools are supposed to respect the people they serve, and the communities they serve. The next generation of children deserves that.”

– Jim McQuillen, Director of the Yurok Tribe Education Department

6cd6151ce1During the first visit to Indian Country by a United States President in fifteen years, President Obama recently described a crisis in Native American education.1 Although the President focused on tribal schools run by the federal government, which are some of the lowest performing schools in the country,2 Native American students across the United States suffer from inadequate educational opportunities. Throughout its history, the United States education system has excluded and devalued its Native American students, resulting in a persistent achievement gap between Native Americans and other students.3 Communities seeking to improve educational opportunities for Native students face many challenges, but advocacy approaches from around the country hold the promise of charting a way forward. Given the heterogeneity of Native American tribes and students, these advocacy approaches can be successful only when adapted to celebrate local strengths and recognize local needs.4

Historically, the purpose of educating Native American children in the United States was to assimilate and “civilize” them. Children were removed from their homes and communities, placed in boarding schools or taught in missionary schools, and prohibited from using their languages, practicing their customs, or exhibiting any form of Native culture.5 Although this assimilation policy was eventually abandoned in the 1970s,6 the legacy of discrimination and segregation in education remains. Recent data show that Native American students lag behind other students in a range of measures of academic achievement: in 2011, fewer than 20 percent of Native fourth graders were proficient or advanced in reading and math, as compared with more than 40 percent of their White peers.7 In 2011-12, the high school graduation rate for Native students was 67 percent, the lowest of any racial/ethnic group.8

There is also evidence that Native students are excluded from school more frequently than their peers. A 2013 study of Arizona public school data found that the rates of discipline referrals for Native American students were almost three times higher than those of White students.9 Native American students were also more likely to receive out- of-school suspensions than all other students.10 Schools also push out Native students to independent study programs or alternative school at disproportionately high rates, rather than providing needed supports in mainstream schools.11 This push-out can segregate Native American students and harm their future opportunities because alternative schools often provide less instruction, less academic support, fewer extracurricular activities, and reduced access to college-prep coursework.12

These negative outcomes have their roots in explicit and implicit biases that make Native American students feel unwelcome in school.

Explicit biases manifest themselves in various ways, including:

  1. The use of sports team names and mascots that perpetuate stereotypes;
  2. Taunting and slurs by other students and staff. For example, students in the Pit River Tribe in California have complained of being called “wagon burners” by other students and being told that “redskins are going to be burned.”13 Native students in Loleta, California have complained that the school principal grabbed a Native student’s ear and said “see how red it’s getting”;14
  3. Inaccurate or inappropriate school curricula that fail to recognize the importance of Native American events or holidays, fail to teach about important Native figures, or mishandle Native American history;
  4. Penalties levied on students for participation in cultural traditions, such as prohibitions on students wearing their hair long or wearing traditional clothing or regalia.15 Many schools also penalize students for attending important cultural and spiritual activities and events, such as fishing, dances, and funerals, leading students who attend those events to accrue truancies or fall behind in schoolwork.16

The decades-long nationwide debate about Native American sports team names and mascots demonstrates that many people in the United States still have false and negative stereotypes of Native Americans. Although some teams have dropped the names and mascots and some states have made efforts to eliminate their use completely,17 others fight vigorously to keep them. Courts have upheld state and local government efforts to maintain their mascots, even after Native Americans have complained that they were offensive.18

A new report by the Center for American Progress argues that perpetuating these stereotypes is bad for both Native and non-Native students.19 Almost a decade ago, the American Psychological Association recommended the retirement of all Native American mascots, team names, and symbols, concluding that they harm students of all backgrounds because they perpetuate negative stereotypes and teach students that stereotyping is acceptable, create a hostile environment for Native students, and harm their cultural identities and mental health.20

The new report highlights additional research showing the adverse impact that mascots and other negative images of Native Americans have on Native students’ mental health. Specifically, studies show that exposure to Native American mascots leads to lower self-esteem, decreased sense of community worth, and negative views of students’ self potential.21 Studies also show that negative associations about mascots predict negative associations of real Native people.22 While mascots are only one piece of a larger culture of bias against Native Americans, advocates can harness this research to push for change on behalf of Native students.

Beyond these more explicit forms of discrimination, implicit biases and unconscious negative stereotypes can affect both how people treat Native students in schools and how students perceive themselves. Negative stereotypes of Native Americans as foreign, unintelligent, violent savages continue to permeate most people’s unconscious perceptions of Native Americans.23 Dr. Stephanie Fryberg notes that, because of the relative invisibility of Native people in mainstream culture, stereotypes shape perceptions and constrain individual identity formation.24 In the school context, these beliefs are harmful. For example, beliefs that Native students are less intelligent can lead to lower expectations,25 both by teachers and students, about students’ potential, which ultimately lead to lower performance. Similarly, teachers’ or school administrators’ biases about students’ propensities for violence or aggression may lead to disparate school discipline.26 Dr. Fryberg has found that these negative social representations of Native Americans impact how Native students see themselves, leading to lower self-esteem, negative beliefs about possible achievement, and negative attitudes about community power and resources, all of which can contribute to dropout and low achievement.27

Tackling these complex problems requires an approach that increases supports for individual students, creates a more inclusive and culturally sensitive school climate, and engages community members and families.

Identifying Reform Goals

Before beginning advocacy on behalf of Native American students, advocates must determine what goals will best serve the students in a specific community. Although Native students, as a group, continue to experience discrimination and unequal educational opportunities, they comprise a highly heterogeneous group, with varying needs and strengths depending on local and regional history, cultural differences, and access to resources.28 Thus, any educational reform effort must involve the local community—including students, their families, tribal leadership, and Elders—in identifying the goals the community hopes to achieve through reform efforts, and crafting clear, measurable targets that can be tracked over time. These goals should drive both the advocacy strategy and the remedies sought. Depending on the needs of a particular community, the objective of the reform efforts may be:

  • Outcome-driven, such as a focus on increasing the number of Native American students that graduate high school within four years, or decreasing the number of suspensions and expulsions of Native American students; or
  • Process-driven, such as improving the complaint process for incidents of racial harassment in schools, encouraging changes in the leadership structure, or creating a parent committee to propose and adopt school programs to support Native students.

Often, a reform effort will have goals that combine these two types of objectives.29 Regardless of the precise goal, defining the objectives is critical both at the beginning of the reform effort, to ensure that appropriate strategies are selected, and at the end, to assess whether the desired results have been achieved.

Although reform efforts must be locally grounded, past reform efforts and academic research provide a framework for how to increase educational opportunities for Native American students. An overarching theme is the need to create culturally sensitive schools. Culturally sensitive schools can shift the educational experience so that Native students can engage and succeed in school without having to deny their cultural identities.30 Studies have demonstrated that schools that are inclusive, intolerant of racism, and supportive of Native American culture and heritage improve school behaviors, motivation, academic outcomes, and overall learning of Native American students.31

Around the country, communities have been able to achieve reforms that help create culturally sensitive schools through attention to:

  • Curriculum and recognition of Native languages,
  • School environment and pedagogy,
  • Professional development and student-teacher relationships,
  • Parent/community involvement, and
  • Anti-discrimination policies.32

Culturally Sensitive Curriculum

In some communities, creating a culturally sensitive curriculum may be a key advocacy goal. Many students process material better when academic abstraction is tied to their identities and everyday realities.33 For Native students, incorporating Native American history, culture, and heritage into the curriculum can be immensely valuable. A review of state content standards that include Native American studies suggests that the following topics should be incorporated into culturally sensitive curricula: local history, including history before and after European American contact; impact of European contact on Native Americans; cultural contributions of Native Americans to American and local society; important Native American figures; local languages; current government policies related to Native Americans; and current issues in Native American society.34

Culturally based curricula have these topics woven into other subject areas; the material is not presented in separate subjects or classes, or as decontextualized pieces of “Indian” culture that perpetuate stereotypes.35 Around the country, schools that serve Native students are experimenting with culturally competent math,36 science,37 and art programs,38 which integrate traditional knowledge with Western content. In the Zuni Public School District in New Mexico, students interview tribal citizens and write a book based on the interviews for their social studies class, investigate traditional agricultural methods in their science class, and collaborate with a Phoenix museum on art projects reflecting traditional and modern Zuni art.39

The Value of Teaching Native American Languages

Studies show that learning traditional languages in schools boosts Native American students’ academic achievement and self-esteem.40 Language classes also provide an opportunity to teach about and connect both Native and non-Native students to culture and history. Schools may need to make institutional changes to ensure that Native language classes are valued and incorporated equally into the school curriculum and are appealing to students and staff.41 Some prerequisites include:

  • A coherent language plan that allows students to progress from beginner to proficiency levels; and
  • District, statewide, and federal recognition of the language to ensure proper funding, teacher accreditation, and credit accrual for students.42

In several districts in Del Norte County and Humboldt County, California, schools, with the help of local tribes, offer languages classes teaching the Native languages Hoopa, Yurok, and Karuk. The classes meet the foreign language requirements for preparatory classes for California’s university systems.43 Other districts have established alternative accreditation programs for teachers of Native languages to account for the fact that many teacher education programs do not train teachers in Native languages.44

Curricular materials also have a large impact on the inclusiveness of school curriculum and ultimately on students’ understanding and perceptions of Native Americans. With only a few exceptions, high school textbooks used in United States, represent Native Americans as artifacts of history, rather than members of contemporary society.45 Given the scarcity of readily available textbooks and the primacy of curriculum in shaping student understandings, an advocacy goal might be to ensure that school curricula are supplemented with sources that accurately represent the Native American perspective. This should be done through collaboration with local tribes and community members.

Culturally Sensitive School Culture, Structure, and Pedagogy

Culturally sensitive schools adapt to students’ needs beyond just the content of the curriculum. Students’ styles of learning in the classroom can be deeply affected by their ways of learning at home.46 When students’ learning styles are mismatched with the classroom, it can leave students feeling both academically unsuccessful and culturally alienated. Thus, advocacy efforts may seek pedagogy that can flexibly adapt to different learning and assessment styles.

In many Native cultures, Elders, parents, and community members are central to traditional education, and cooperation and community are emphasized over individual achievement.47 Children learn through observation, role modeling, story telling, and experience.48 A review of literature on Native American student learning styles found they often: (1) seek a global or holistic understanding of new information; (2) reflectively process problems before responding to questions, (3) tolerate higher levels of ambiguity; and (4) prefer collaboration for task completion, rather than competition and individual success.49 Of course, learning styles vary greatly both across and within Native American tribes, so advocates should be cautious about stereotyping Native students when seeking pedagogical changes.50

Finally, communities may seek additional concrete changes to make the school environment reflect cultural inclusion by:

  • Making the physical space culturally inclusive, such as by posting imagery celebrating Native American leaders, holidays, and traditions;
  • Supporting extracurricular activities that contribute to or reinforce Native American culture, such as facilitating school clubs, and giving students credit and excusing absences for attendance at community or cultural activities outside of school;
  • Creating school administrative structures and policies that welcome student and family involvement, such as Indian Education programs or committees;51 and
  • Allowing students to merge their traditions with school traditions, such as permitting Native students to wear eagle feathers at graduation ceremonies.52

Including Parents and Communities

Studies show that parent involvement is a key, if not the most important, factor in student academic achievement.53 A 2008 study of Montana school data shows that parent involvement is the most important factor in high academic achievement for Native American students, outweighing teaching, leadership, and curriculum.54

However, Native American families face a number of barriers to participation in their children’s education, which must be considered by any advocacy efforts seeking to include parents in educational improvement:

  1. Historically, education policies and practices deliberately excluded parents and communities from participating in their children’s education. As a result, they may not have models for active participation in school;
  2. Many Native American adults had negative experiences with their own schools; the intergenerational pattern can compound feelings of alienation. Parents may continue to perceive schools as hostile and culturally insensitive, favoring non-Native students and parents. Further, centuries of subjugation and conflict can lead to distrust and anger, hindering effective collaboration and communication between parents and educators; and
  3. There may be financial, scheduling, or transportation barriers to parents’ school involvement.55

Consequently, in some communities, advocacy will be most powerful when it explicitly defines parent inclusion as a goal. Similarly, other stakeholders, such as tribal councils, Elders, or community groups, should be engaged and involved in decision-making about education of Native students. Some specific strategies for fostering positive parent-school relationships include:

  • Personalized invitations or communication to parents in multiple formats (letters, emails, phone calls) to make them feel welcome in school;56
  • Timely and positive communication to parents rather than communication only about negative events;
  • Community-oriented school environment that welcomes visits and participation from parents;
  • Solicitation of input from parents about how to incorporate elements of Native American culture into the school environment;57
  • Encouraging and supporting parent participation in students’ learning at home; and
  • Including parents in decision-making in schools.58

Professional Development and Recruitment

Teachers’ relationships with students also predict motivation and achievement of Native American students.59 Ideally, schools should have teachers and staff representing the various backgrounds of its student body. Unfortunately, many Native American students attend schools that have few or no Native staff members. Advocates can push for schools to affirmatively recruit and hire staff from local Native American communities.60 Tribal education departments and local universities can be important resources in identifying potential staff, and in recruiting and training future staff members.

Given the reality that many Native students will not have Native teachers, professional development on history and culture of local tribes, cultural differences in learning styles, and culturally sensitive classroom management will likely be important for many reform efforts. Additionally, advocates may seek regular training for staff on anti-discrimination policies, discipline,and complaint procedures, and improved professional development through in-service trainings, workshops, and coaching.61 Cultural competency trainings cannot be a one-off, but must be integrated into the culture of teacher education programs and ongoing professional development.

Given the dearth of Native American employees in many schools serving Native students, advocates may be able to argue for hiring district employees dedicated to serving Native American students. These staff can serve as a liaison between parents and the school, providing counseling or special education advocacy to Native students, reporting on data about Native students, or other tasks depending on the needs of the students and community.62

Anti-discrimination policies

Even in the most culturally sensitive school, it is important that school districts make explicit that discrimination and harassment based on race are prohibited. Advocacy may need to address anti-discrimination and anti-harassment policies to ensure that they are effective. These policies should be regularly updated with input from students, parents and community members. They should also be clearly presented to students regularly throughout the school year, and made available in a variety of formats to students and families, including being posted in schools, on school and district websites, and distributed to students and families.

Without a robust complaint and investigation procedure, anti-discrimination and anti-harassment policies are meaningless. Thus, students and families should know where, when, how, and with whom complaints should be filed. The policies should be in easily understandable language. The policies must also delineate who is responsible for investigating, steps they should take in the investigation, timelines for completing the investigation, and guidelines for informing students and families about the resolution. Complaint procedures should also specify where and for how long records of complaints should be maintained. Finally, the policies should indicate that retaliation is illegal, and that people who retaliate will be punished.

Once communities and advocates determine necessary reform goals, they must work together to determine the advocacy strategy that will best achieve those goals. The second part of this article, which will be published in the next edition of Youth Law News, will describe potential advocacy strategies and communities that have used those strategies to achieve specific reforms

Mae Ackerman-Brimberg was a Social Justice Fellow at the National Center for Youth Law until August 2014. At NCYL, Mae worked on Federal civil rights complaints involving the the treatment of Native american students in the Loleta Union School District and the Eureka City Schools District. She is currently clerking for a federal judge.



  1. Mark Lander, Obama Visits Sioux Lands on a Trip Overshadowed By Iraq, N.Y. Times, June 14, 2014, at A15; see also Suzette Brewer, Obama Follows Visit with Strong Action Plan for Indian Country, Indian Country Today Media Network (June 16, 2014),
  2. U.S. Dep’t of the Interior, Indian Affairs, Findings and Recommendations Prepared by the Bureau of Indian Education Study Group, 5 (June 27, 2014), (hereinafter “BIE Recommendations”). In the 2007-2008 school year, the federal government, through the Bureau of Indian Education (“BIE”) funded 183 schools; approximately two-thirds are tribally operated under BIE grants, while the remaining one-third are run by the BIE. U.S. Dep’t of the Interior, Indian Affairs, The Bureau of Indian Education (BIE), (last visited Oct. 6, 2014) (hereinafter “BIE What We Do”).
  3. This article uses the term “Native American” or “Native” to refer to people indigenous to the United States. Recognizing that this covers a diverse group, it is intended here to include people who identify as American Indian (referring to the continental U.S.), Alaska Native, and Native Hawaiian, or other indigenous peoples not listed here. Because these groups are not always grouped together in laws, policies, or data collection, readers should be cautious about usage of the various terms.
  4. There are 566 federally recognized American Indian and Alaska Native tribes. This does not include Hawaii Natives. U.S. Dep’t of the Interior, Indian Affairs, Tribal Directory, (last visited Oct. 6, 2014).
  5. Throughout the 20th century, many of the boarding schools evolved into day schools, though still run by the federal government. BIE Recommendations, supra note 2, at 1-2. See also Great Lakes Equity Center, The State of American Indian Education: Equity Considerations (2013),
  6. BIE What We Do, supra note 2; John Echohawk, The Kennedy Report, 41 NIEA News 16 (Winter 2009/2010),
  7. The Education Trust, The State of Education for Native Students 5 (2013),
  8. The graduation rates of other ethnic groups were as follows: 88% for Asian/Pacific Islander students, 86% for White students, 73% for Latino students, and 69% for African American students. Rebecca Klein, The Education System is Failing Native American Students. Here’s Proof, The Huffington Post, July 18, 2014,
  9. Carolyn Brown & Caterina Di Tillio, Discipline Disproportionality among Hispanic and American Indian Students: Expanding the Discourse in U.S. Research, 2 J. Educ. & Learning 47, 51-52 (2013),
  10. Id. at 52.
  11. Susan C. Faircloth & John W. Tippeconnic III, The Civil Rights Project/Proyecto Derechos Civiles at UCLA, The Dropout/Graduation Rate Crisis Among American Indian and Alaska Native Students: Failure to Respond Places the Future of Native Peoples at Risk, 27-28 (2010),; Northern Arizona University, American Indian School Dropouts and Pushouts, (last visited Oct. 6. 2014).
  12. See, e.g., Dignity in Schools Campaign, Alternative Schools and Pushout: Research and Advocacy Guide,
  13. Marc Dadigan, ‘Watch Your Red-Skinned Back’: Racist Notes Surface in California Schools, Indian Country Today Media Network (Mar. 18, 2014),; Telephone Interview with Delia Parr, Directing Attorney, California Indian Legal Services (July 7, 2014).
  14. Letter from the American Civil Liberties Union Foundation of Northern California, the National Center for Youth Law, and California Indian Legal Services to U.S. Dep’t of Educ., Office for Civil Rights, San Francisco Office, (Dec. 18, 2013), at 8,
  15. Telephone Interview with Delia Parr, Directing Attorney, California Indian Legal Services (July 7, 2014).; see, e.g., Tanya Lee, High Schooler First Not Allowed, Then Allowed, to Wear an Eagle Feather in Graduation Cap, Indian Country Today Media Network (Nov. 28, 2011),; Lewis Griswold, Lemoore High’s Native American Grads Allowed to Wear Eagle Feathers, The Fresno Bee (June 5, 2014),
  16. Adrienne Freng et al., Models of American Indian Education: Cultural Inclusion and the Family/Comminuty/School Linkage. 39 Soc. Focus 55, 65 (2006).(studying student perceptions about family/school interactions, inclusion of Native American history in curriculum, and student experiences and role expectations in school) (hereinafter “Models of Indian Education”).
  17. In 2013, the Michigan Department of Civil Rights (“MDCR”) filed a complaint with the U.S. Department of Education’s Office for Civil Rights (“OCR”) asking the agency to issue an order prohibiting the use of American Indian mascots, names, and other imagery. See Michigan Dep’t of Civil Rights, Michigan Department of Civil Rights: Continued Used of American Indian Mascots Hurts Student Achievement,,4613,7-138–294605–,00.html (last visited (Oct. 6, 2014). OCR dismissed the complaint on May 29, 2013, because MDCR had not provided specific examples of race-based incidents or identified individual students who had suffered harm. See Letter from Catherine D. Criswell, Director, U.S. Dep’t of Educ., Office for Civil Rights Region XV, to Daniel M. Levy, Director of Law and Policy, Mich. Dep’t of Human Rights (May 29, 2013) (OCR Docket Ref. Nos. 15-13-1120 to 15-13-1154),
  18. Dupuis v. Board of Trustees, 2006 MT 3 (Mont. 2006); Ill. Native Am. Bar Ass’n v. Univ. of Ill., 368 Ill. App. 3d 321 (App.Ct.Ill., 1st Dist., 2nd Div. 2006).
  19. Erik Stegman & Victoria Phillips, Center for American Progress, Missing the Point, The Real Impact of Native Mascots and Team Names on American Indian and Alaska Native Youth, 4 (2014), (hereinafter “Missing the Point”).
  20. Id.; American Psychological Association, APA Resolution Recommending the Immediate Retirement of American Indian Mascots, Symbols, Images, and Personalities by Schools, Colleges, Universities, Athletic Teams, and Organizations (2005),
  21. Stephanie A. Fryberg, American Indian Social Representations: Do They Honor or Constrain American Indian Identities? Conference Presentation, 50 Years after Brown v. Board of Education: Social Psychological Perspectives on the Problems of Racism and Discrimination, University of Kansas 5-9 (May 13-14, 2004) (hereinafter “Social Representations”); see also Stephanie A. Fryberg & Nicole M. Stephens, When the World is Colorblind, American Indians Are Invisible: A Diversity Science Approach, 21 Psych. Inquiry 115 (2010) (hereinafter “Colorblind”); John Chaney et al., Do American Indian Mascots = American Indian People? Examining Implicit Bias Towards American Indian People and American Indian Mascots, 18 Am. Indian Alsk. Native Ment. Health Res. 42, 54 (2011) (hereinafter “Implicit Bias Towards AI People and Mascots”); Missing the Point, supra note 19.
  22. Implicit Bias Towards AI People and Mascots, supra note 21, at 54.
  23. Susan K. Serrano & Breann Swann Nu’uhiwa, Federal Indian Law: Implicit Bias Against Native Peoples as Sovereigns, in Implicit Racial Bias Across the Law 209, 210, 214-24 (Justin D. Levinson & Robert J. Smith eds., 2012). Serrano and Swann Nu’uhiwa also argue that these implicit associations have been codified into and legitimized through law.
  24. Social Representations, supra note 21, at 5-9; see also, Colorblind, supra note 21,.
  25. Implicit Bias Towards AI People and Mascots, supra note 21, at 54; Models of Indian Education, supra note 16, at 66.
  26. Although there are very few studies about the impact of implicit bias against Native Americans, studies show that these biases affect expectations and perceptions of behavior of African American students. See, e.g., Kent D. Harber, et al., Students’ Race and Teachers’ Social Support Affect the Positive Feedback Bias in Public Schools, 104 J. Educ. Psychol. 1149-61 (2012); Cheryl Staats, State of the Science Implicit Bias Review 2013, The Ohio State University Kirwan Institute for the Study of Race and Ethnicity 30 (2013),; Dominik Becker, The Impact of Teachers’ Expectations on Students’ Educational Opportunities in the Life Course: An Empirical Test of a Subjective Expected Utility Explanation, 25 Rationality & Soc’y 422, 429 (2013); Danfeng Soto-Vigil Koon, Exclusionary School Discipline: An Issue Brief and Review of the Literature, The Chief Justice Earl Warren Institute on Law and Social Policy, Univ. of Cal. Berkeley 6 (April 2013),
  27. Social Representations, supra note 21; Colorblind, supra note 21. The impact on self esteem, self worth, and identity is particularly worrisome, given that Native American adolescents and young adults have rate of suicide 2.5 higher than the national average. Missing the Point, supra note 19, at 7.
  28. Martin Reinhardt et al., Interwest Equity Assistance Center, A Descriptive Account of the Best Practices in American Indian Education On-Line Seminar Pilot Project 13,
  29. North Central Comprehensive Center for the North Dakota Dep’t of Educ., American Indian Education: Review of Research Highlighting Parent Involvement, Extended Learning Opportunities, and State Takeovers 5 (2010) (hereinafter “NCCC, Review of Research”).
  30. Missing the Point, supra note 19; American Psychological Association, APA Resolution Recommending the Immediate Retirement of American Indian Mascots, Symbols, Images, and Personalities by Schools, Colleges, Universities, Athletic Teams, and Organizations (2005),
  31. Navin Kumar Singh, Culturally Appropriate Education Theoretical and Practical Implications, in Honoring Our Heritage, Culturally Appropriate Approaches for Teaching Indigenous Students 11, 13 (John Reyhner, Williard Sakiestewa Gilbert, Louise Lockard, eds. 2011), (hereinafter “Honoring Our Heritage”); Models of Indian Education, supra note 16, at 66.
  32. For example, Alaska’s Standards for Culturally Responsive Schools covers culturally sensitive content standards to define what students should be learning and should know, in addition to performances standards for teachers and administrators, and quality school standards used in the school accreditation process. Alaska Native Knowledge Network, Alaska Standards for Culturally-Responsive Schools (Feb. 3, 1998),
  33. Implicit Bias Towards AI People and Mascots, supra note 21, at 54; Abner Oakes & Traci Maday, The Center for Comprehensive School Reform and Improvement, Issue Brief: Engaging Native American Learners with Rigor and Cultural Relevance (2009) (summarizes initiatives in Zuni, New Mexico, Denver, Colorado, and Hoopa, California), (hereinafter “Engaging Native American Learners”). Some states, including Arizona, Montana, North Dakota, Oklahoma, Oregon, Wisconsin, Arizona, and New Mexico have incorporated some level of Native American studies into their statewide content standards. North Central Comprehensive Center for the Minnesota Dep’t of Educ., American Indian Education Contributions: How Are These Incorporated Into States Social Studies Standards? 4 (2009) (“AI Contributions in State Standards”); Honoring Our Heritage, supra note 31, at 15; NCCC, Review of Research, supra note 29, at 8.
  34. AI Contributions in State Standards, supra note 33, at 4.
  35. Willard Sakiestewa Gilbert, Developing Culturally Based Science Curriculum for Native American Classrooms, in Honoring Our Heritage, supra note 31, at 44; James W. Bequette & Kelly Hrenko, Culture-Based Arts Education, in Honoring Our Heritage, supra note 31, at 97; Gilliland, Curriculum Development for American Indian Students 1, 7 (1987),
  36. Honoring Our Heritage, supra note 31, at 45.
  37. Id., at 43.
  38. Id., at 97.
  39. Engaging Native American Learners, supra note 33.
  40. Phyllys Bo-yuen Ngai, An Emerging Native Language Education Framework for Reservation Public Schools with Mixed Populations, 47 J. Am. Indian Educ. 22, 25 (2008).
  41. For a discussion about both Native and non-Native points of view about Native language instruction, see id., at 25-26.
  42. Id., at 32-34.
  43. Engaging Native American Learners, supra note 33; Telephone Interview with Jim McQuillen, Education Director, Yurok Tribe (Aug. 4, 2014).
  44. Telephone Interview with Delia Parr, Directing Attorney, California Indian Legal Services (July 7, 2014).
  45. Carolyn A. Brown, The Struggle to be Seen: Changing Views of American Indians in U.S. High School Textbooks, in (Re)Building Memory: School Textbooks, Identity, and the Pedagogies and Politics of Imagining Community 32 (J. W. Williams, ed., in press).
  46. Cornel Pewewardy, Learning Styles of American Indian/Alaska Native Students: A Review of the Literature and Implications for Practice, 41 J. Am. Indian Educ. 22, 25-27 (2002) (hereinafter “Learning Styles”).
  47. Models of Indian Education, supra note 16, at 60; NCCC, Review of Research, supra note 29 at 8; H. Hammond et al. Culturally Relevant Classroom Management Strategies for American Indian Students, 23 Rural and Special Educ. Q. 3-9 (2004); Learning Styles, supra note 46, at 42; Andre Cramblit, Teaching Native American Students, Native and Western Learning Styles Compared,
  48. Learning Styles, supra note 46, at 27.
  49. Learning Styles, supra note 46; NCCC, Review of Research, supra note 29, at 8.
  50. Learning Styles, supra note 46, at 24-25, 48.
  51. Honoring Our Heritage, supra note 31, at 15, 19; AI Contributions in State Standards, supra note 33, at 11.
  52. See, e.g., Lewis Griswold, Lemoore High’s Native American Grads Allowed to Wear Eagle Feathers, The Fresno Bee (June 5, 2014),
  53. NCCC, Review of Research, supra note 29, at 9-10.
  54. NCCC, Review of Research, supra note 29; Models of Indian Education, supra note 16, at 60.
  55. Dawn A. Mackety & Jennifer A. Linder-VanBerschot, U.S. Dep’t of Educ., Institute of Education Sciences, National Center for Education Evaluation and Regional Assistance, Regional Educational Laboratory Central, Examining American Indian Perspectives in the Central Region on Parent Involvement in Children’s Education, 12 (2008),
  56. Due to high levels of poverty and large populations in rural areas, some families may not have Internet access. Therefore, using multiple forms of communication can be critical to facilitating effective parent involvement. Id.
  57. Id., at 11-16.
  58. Models of Indian Education, supra note 16, at 62.
  59. See NCCC, Review of Research, supra note 29, at 7.
  60. In the Del Norte and Bishop settlements, for example, the district committed to making efforts to recruit and hire diverse staff. Del Norte County Unified Sch. Dist., Reduction in Student Discipline Agreement, §2(d), April 30, 2009 (on file with author); Bishop Union Elementary Sch. Dist., Settlement Agreement, §3(b), Sept. 12, 2007,
  61. NCCC, Review of Research, supra note 29, at 7.
  62. Consent Decree at 6, Antoine v. Winner Sch. Dist., No. 06-3007 (D.S.D. Dec. 10, 2007),; Telephone Interview with Courtney Bowie, Senior Staff Attorney, American Civil Liberties Union Racial Justice Program (July 29, 2014); Telephone Interview with Delia Parr, Directing Attorney, California Indian Legal Services (July 7, 2014).