Indigenous Peoples' Day Featuring Eliza "Lyda" Burton Conley

GLO Record of the Week for October 9, 2022

On October 8, 2021, President Joe Biden signed a presidential proclamation to formally recognize October 11th as Indigenous Peoples' Day. As a national holiday, this day is to celebrate and honor Native American peoples, their histories, and cultures.

An Indigenous Peoples' Day celebration in Berkeley, CA

Indigenous Peoples' Day started as a counter-celebration to what is known as Columbus Day. The first protest was started by Colorado's American Indian Movement chapter back in 1980. In 1989, with the help of activists, South Dakota replaced Columbus Day with Native American Day. Then, in 1992, the city council of Berkeley, CA formally adopted Indigenous Peoples' Day during the 500th anniversary of Columbus' first voyage. Since then, many other states and cities adopted the holiday to what is now a nationally recognized holiday.

In honor of Indigenous Peoples' Day, this Record of the Week is featuring Eliza "Lyda" Burton Conley, a member of the Wyandotte Tribe of Kansas.


Conley was born between 1868 and 1869 to Eliza Burton Zane Conley and Andrew Conley. Her mother was a member of the Wyandotte (Wyandot/Wyandott) tribe and a descendant of a chief and her father was an English farmer. She became a lawyer, was admitted to the Missouri Bar, taught at Spalding Business College in Kansas City, had telegraphic operator training, and was a Sunday School teacher at the Methodist Episcopal Church. Here, you can see the patent for the church approved on September 16, 1861.

Conley was best known for her fight to protect the Huron Indian Cemetery, now formally known as the Wyandot National Burying Ground in downtown Kansas City. The cemetery was established in 1843 when the Wyandotte tribe was forced to move from their home in Ohio. Many died on that journey and their bodies were laid to rest on a ridge near the fork of the Kansas and Missouri Rivers. Some of the tribe moved on to Oklahoma and some stayed in Kansas City, which was called the town of Wyandott at the time.

The earliest plat of the area was surveyed in 1856 by Samuel Parsons and approved by Survey General John Calhoun in 1857. You can see that a road going east to west says "Road from Leavenworth to Wyandott". That road should lead up to the cemetery in the northwest part of section 10, but it is not delineated here.

The cemetery would be in the northwest corner of section 10, but it is not delineated here.

As the downtown area started to grow, developers were looking to build on that land. Conley did not stand for that. Instead, she went to the Kansas City School of Law to prepare to fight and was one of the only women to graduate in her class of 1902.

Here you can see the location of the cemetery in real time, compared to where it would be on the plat from 1857

In 1906, Congress approved selling the land and moving the graves, but Conley filed against the US Secretary of the Interior and Indian Commissioners in the US District Court to prevent it from happening. She and her sister built a blockade known as "Fort Conley" in front of the cemetery to protect it from trespassers.

Conley represented herself in front of the Supreme Court on January 14, 1910, as the first Native American woman to do so. She argued that the 1855 federal treaty with the Wyandotte protected them and their descendants from the US selling the land.

Though, she did not succeed in persuading the court, Conley got the attention of Kansas senator, Charles Curtis. In 1913, he passed a law to protect the cemetery from any future development.

Even though that law was passed, Conley did not stop fighting. In 1918 she was arrested multiple times for interfering with city officials who she thought were disrespecting the graves. She also spent 10 days in jail on a trespassing charge while protecting the cemetery in the 1930s. Despite all of that, she continued to protect her ancestors and her heritage throughout her life.

Conley died in 1946 and was placed next to her sister and the other 400-600 people in the cemetery. Her work and her fight did not go unnoticed. In 1971, the Huron Indian Cemetery was added to the National Register of Historic Places and in 2017, the cemetery was designated as a National Historic Landmark.

An Indigenous Peoples' Day celebration in Berkeley, CA

The cemetery would be in the northwest corner of section 10, but it is not delineated here.