Two descendants of Black individuals formerly enslaved by the Muscogee Nation have initiated a federal lawsuit seeking enforcement of their tribal citizenship rights, which were affirmed by the Muscogee Nation Supreme Court last year. The suit was filed Thursday in U.S. District Court in Oklahoma City on behalf of Rhonda Grayson and Jeffrey Kennedy, naming Muscogee Nation Principal Chief David Hill and the tribe’s Citizenship Board as defendants.
Grayson and Kennedy’s applications for tribal citizenship were initially denied in 2019 after the Citizenship Board determined they could not prove descent from a lineal ancestor documented as “Muscogee (Creek) Indian by blood” on the Dawes Rolls, a U.S. government census taken around 1900. However, in July 2025, the Muscogee Nation Supreme Court ruled that Grayson and Kennedy, as descendants of Freedmen—Black individuals once enslaved by the tribe—are entitled to full citizenship under the 1866 treaty between the Muscogee Nation and the United States. That treaty abolished slavery and granted citizenship rights to formerly enslaved people within the tribe.
Despite the court ruling, the Citizenship Board has not issued citizenship cards to Grayson and Kennedy, effectively barring them from participating in tribal elections and other membership privileges. According to the lawsuit, Principal Chief Hill has actively blocked the issuance of citizenship cards, pending decisions on potential amendments to the tribe’s constitution. In August 2025, Hill halted the Citizenship Board’s ability to distribute these cards until such constitutional considerations are addressed.
The Muscogee Nation’s constitution, adopted in 1979, limits membership to those who can trace ancestry directly to individuals identified “by blood” on the Dawes Rolls, effectively excluding descendants of Freedmen who were listed separately. This constitutional provision has been a point of contention, given the 1866 treaty’s guarantee of citizenship to formerly enslaved persons.
The Muscogee Nation is one of five Native American tribes in Oklahoma that historically practiced slavery. Its tribal headquarters is located in Okmulgee, approximately 100 miles northeast of Oklahoma City. Efforts to obtain comment from Principal Chief Hill and the Citizenship Board have so far been unsuccessful.
The lawsuit seeks to compel the tribal leadership to comply with the Supreme Court’s ruling and to recognize the tribal citizenship rights of Grayson, Kennedy, and others similarly situated, reaffirming their ability to participate fully in the affairs of the Muscogee Nation.
