According to the petitioner, leadership authority was vested predominantly in the heads of families until the establishment of the group's council in the 1970's. In accordance with the petitioner's claim to being "underground" for a number of years, the group explains the absence of documentary evidence of leaders by maintaining that these individuals were likewise hidden. The 1986 Response includes a quote which the petitioner maintains describes the group's notion of leadership:
The Anglo understands power from what he sees in the leaders of a given group. Those leaders [sic] actions are recorded and made history. For two hundred years our people haven't had any leaders stand up out of our circles for the Anglo in this part of the country to view and to understand. Therefore, for 200 some odd years our people have blended. We've disappeared. We still don't have leaders as you understand them. We have people who go out and share our feelings and our opinions today with the [non-Indian] community. We are trying to let people know who we are here, there are more of us.... (SSA 1986.05.23 [Addendum B], 122)
The petitioner submitted a document entitled "Family History and Leadership Chart" (SSA 1996.01.17 [Part B, Appendix 2]) as part of an appendix to the 1986 Response. According to the petitioner, through the oral traditions of the Abenaki community, many of the leaders have been identified for the 1900 to 1985 period and are listed in an Appendix here" (SSA 1986.05.23 [Addendum B], 123). The petitioner did not include a description of how this information was gathered, or cite the particular "oral traditions" from which this information was said to have been gleaned.
This list contains the names of a number of people whom the petitioner described as leaders during the 20th century, but the group has not included information as to what qualified these individuals to be called leaders, other than that they were the parents of particular families. For example, the petitioner has not identified any activities which these people played a role in organizing. The petitioner did not identify instances in which an individual was called upon to render assistance to another member. The petitioner has not offered evidence that people in the larger community acknowledged these people were influential within the community as a whole, not just within their own families. The petitioner has offered no explanation as to why, if the group was so concerned with hiding from "Angles," none of the Indian groups in New England acknowledged any leaders of this group. The petitioner has also not offered sufficient information to demonstrate that people within the group looked at these individuals as leaders. The petitioner should provide examples of this type of information to demonstrate that these people were actually leaders, and to provide evidence of their leadership activities.
Many of the petitioner's ancestors came from very large families, married other people from equally large families, and then went on raise large families of their own. The size of these families led the petitioner to state that having a large family was "commonly the baseline and essential starting point for any leader" (SSA 1996.01.17 [Part B Appendix 8], 163). The petitioner should demonstrate that the individuals it identifies ash leaders not only influence their
Maintaining Order in ''Back Bay"
The petitioner maintains that Nazaire St. Francis Jr. (1890-1960) was one of the family leaders among the members of the "Back Bay" area, just as it claimed that his father had been in the late' 19th-century. According to the petitioner,
Nazaire St. Francis Jr. raised as many as six gardens at different locations in the Back Bay, and regularly distributed the extra food to families that were short. In some cases, he even donated food to St. Anne's School to help cover the cost of tuition for his children when he had no other means of paying the fee. (SSA 1982 10.00, 94) (78.)
Distributing extra produce from gardens does not necessarily show leadership. The petitioner should demonstrate that Nazaire St. Francis's generosity stemmed from his responsibilities as as Abenaki community leader. Further, the petition states that Nazaire St. Francis gave the St. Anne's School (79.) vegetables when he was unable to afford to pay his children's tuition, but does not include information as to whether he ever contributed to the tuitions of children outside of his family.
Another interview indicates that St. Francis would sometimes intervene in domestic problems:
...He was broad-shouldered, thick set -- if he got his hands on you; you did what he wanted you to do. He was in a similar position to [Arthur] Gene Cote (1822-1937) [a claimed ancestor of some members of the group]. He lived farther down the street and he took care of his end. He'd take care of the lower section, like down where the Brows lived; more or less keeping the place law abiding. But if one of the boys stole chickens and got caught, then the law would come in, and there wasn't anything we could do. (Wells, Bob and Alma, 1982.03.18, 9)
This description suggests these men were able to assert some limited authority over some people outside their nuclear families, possibly due to the force of their personalities. However, another quote also indicates that this community authority was not limited to these two men:
78. An outsider is quoted in Wiseman's The Voice of the Dawn as saying "I remember when I was a kid; we had a (Indian) Chief in town" (Gravel quoted in Wiseman 2001, 144). Wiseman tentatively identifies the "chief' as Nazaire St. Francis (Wiseman 2001, 145). However, the quote does not include the name of the man remembered as "chief," nor does it include a description of his activities. The quote also does not include an explanation of what led the man to believe that the man he remembered was actually a "chief."
79. St. Anne's Catholic School opened in 187 (http://www.swantonhistoricalsociety.org/, 7), and was staffed predominantly by French and French-Canadian nuns from the Sisters of the Holy Ghost in 1930 (1930 US Census). No other information about the school has been submitted by the petitioner, including information on which of the St. Francis children were supposed to have attended the school, or information of how many other people ancestral to the group attended the school.
This quote indicates that the area was, in some ways, responsible for policing itself. If anyone behaved in an unacceptable fashion, then another person (not just Cote or St. Francis) could intervene and attempt to discipline him or her. The statement also does not indicate whether Cote and St. Francis intervened only in disputes between the petitioner's purported ancestors, or if they involved themselves in the affairs of all residents of the area. The statement also makes the point that external authorities handled "big" issues, although the interview does not indicate what some of those issues might have been (other than stealing chickens). These quotations do not indicate that these men intervened with formal authorities on behalf of those who had committed a "big" crime, or that formal authorities turned to these men to resolve particular issues in their area. The petitioner may wish to discuss specific conflicts (either between its claimed ancestors or between its claimed ancestors and other individuals living in the area) which may have been mediated by Cote or St. Francis, and describe how these disputes were settled.
The petitioner has also made the argument that Cordella (Freemore) Brow was a popular midwife and informal leader who was also responsible for the recording of 20 children as "Indian-White" in town records from 1900 to 1920. However, a review of the actual birth records submitted by the State does not support this assertion (see criterion 83.7(b) for a discussion of this topic). The petitioner may wish to present additional evidence of Mrs. Brow's leadership.
The petitioner argues that, in the years before the development of the group's council, some members began holding informal meetings around various members' kitchen tables (SSA 1982. 10.00 Petition, 104). Although the petitioner has provided some names of participants and a description of some of the topics discussed after 1972 (Wiseman 2001, 153), the earlier years lack detail. The petitioner should include descriptions of any pre-1972 meetings, including when they occurred, the names of the people hosting the meetings, the names of people attending, and the topics discussed.
During this time, the group also maintains that people known as "backstops" or "mouthpieces" served as representatives from the various family groups. The group should provide the names of these people, give more specific examples of the duties they performed, the dates when they served, and how they came to occupy these positions.
The Vermont Eugenics Survey
As was discussed under criterion 83.7(b), the VES followed various "deficient" families and individuals, particularly those who had been institutionalized or involved with the criminal
The Iroquois Land Claims, 1951-1953 (81.)
On April 19,1951, two Canadian Iroquois chiefs from the Two Mountains Reserve in Quebec appeared before the Vermont legislature and presented a claim for $89,000 for land in the northwestern portion of the state, including Franklin, Grand Isle, Chittenden, Addison, and part of Rutland counties (Burlington Free Press 1951.04.19, npn). Gordon Day wrote to Charles Adams, head of a special State commission appointed to investigate Iroquois land claims in northern Vermont, informing him that the St. Francis Indians living in Odanak were the only true heirs to the Abenaki" who had once resided in Vermont. He added, more aggressive claims by Iroquoian groups should not prejudice any claim which the St. Francis Abenakis may have" (Day 1952.12.28, 1).
In 1958, the Iroquois returned to Vermont to continue to press their case. This time, 17 representatives and 200 members from the Caughnawaga, St. Regis, and Oka reserves traveled to Vermont to lobby the legislature. Their lawyer, Roland Stevens, stated that they hoped to gain a settlement of as much as $4 million dollars. The group also planned to erect dwellings on the lawn in front of the State legislature and to perform various dances for the public (Daily Messenger 1958.04.08, A12). (82.) No further evidence was submitted regarding the outcome of the Iroquois claims to land in northwestern Vermont.
Throughout the entire 1950's, there is no available evidence to demonstrate that the petitioner's ancestors protested the claims activities of the Iroquois or joined the lawsuits they filed. No one, including Gordon Day, described any Vermont Abenaki entity living in one of the counties named in the lawsuit. Day, in fact, instead identified the residents of Canada's Odanak reserve as the rightful claimants to the Vermont territory claimed by the Iroquois. The petitioner has provided no evidence of any objections made by a resident group of "Abenaki" in Vermont.
80. As was stated under the discussion of the subject under criterion 83.7(b), there are no available records documenting who was sterilized, only figures identifying how many people were sterilized.
81. Evidence regarding the Iroquois land claims was submitted by the State; the petitioner submitted no evidence regarding these claims.
82. Squires, in her 1996 thesis, attributed the presence of wigwams on the lawn of the State capitol to the activism of the St. Francis family protesting the State's decision to take the Missisquoi delta as a wildlife refuge (Squires 1996, 61). Yet, there is no available evidence of participation by the St. Francis family or any other families from the petitioning group in the land claims activities of the 1950's; further, there are no available newspaper accounts or other accounts of protests launched by the petitioning group against the establishment of the Missisquoi wildlife refuge.
According to Wiseman, the "council" that the group organized in 1975 was an evolution of a number of informal meetings that had been taking place (Wiseman 2001, 152). Wiseman identified individuals such as `'Wayne Hoague (unknown), Kew Ouimette (unknown), Richard Phillips (1937-unknown), Robert Wells (1922-after 1983), and Homer St. Francis (1935-2001) as participating in these meetings. However, the group has not included interviews or other information detailing when these meetings took place or what specific topics were discussed. The petitioner is encouraged to provide considerably more details of these informal meetings, including when they occurred, who attended, what topics were discussed, and what (if any) actions were taken as a result of the discussions.
The petitioner has presented considerable documentation regarding the group's political activities after the early 1970's. Documentation submitted by the group includes, but is not limited to, minutes from the ASHAI, group council minutes, newspaper articles, scholarly monographs, court documents, and correspondence between the group's representatives and various government officials and agencies. The State has submitted documentation including, but not limited to, newspaper articles, court documents, and scholarly monographs.
ASHAI and the Abenaki Council
Petitioner researcher Frederick Wiseman asserts that the formation of the "Tribal Council" was an outgrowth of informal meetings which had taken place in previous years. However, documentation included in the petition narrative and in support of the petition indicates that the real catalyst in the organization of the group was Ronnie Cannes, who worked for the Boston Indian Council in the early 1970's. Cannes came to Vermont to establish an Indian Manpower Office and to take a census of Indians in Vermont. (83.) Before the early 1970's, there is no available evidence that Cannes had ever met or associated with members of the Swanton group. Cannes is cited in the 1982 petition as providing a "vision of organization and social action" (SSA 1982. 10.00 Petition, 105), and encouraging the group to organize itself into a council." The body that was formed appears to have been the Abenaki Self-Help Association, Inc. According to documents submitted by the petitioner, ASHAI was established in 1975 (ASHAI 1984.00.00, 2), and there is some indication that ASHAI served as the group's governing body. For example, Cannes testified at a hearing of the American Indian Policy Review Commission Task Force Hearing on Non-Federally Recognized and Terminated Indians in 1976 and was introduced as a representative of the "Abenaki Tribal Council" (AIPRC 1976.04.09). The "Abenaki Tribal Council," was not formed until late 1976 or 1977 (Abenaki Tribal Council 1977.00.00, 1).
83. Although the 1982 petition referred to Cannes as "a young Abenaki from St. Johnsbury," the 2005 membership list includes Cannes in the "3" category ("Needs More Information").
84. Wiseman, however, does not mention Cannes or the Boston Indian Council in his discussion of the origins of the group's council (Wiseman 2001, 151-60).
The petition contains copies of ASHAI minutes from 1978 to 1984, and then again from 2001 to 2005, a total of 10 years. However, the information submitted by the petitioner includes only a portion of the organization's minutes. The group submitted some minutes from 1978 to 1984, but submitted no minutes for the following 17 years. It did submit additional minutes for the post-2001 period, when the ASHAI board began to hold joint meetings with the group's governing body. Further, the minutes of the organization from 1978 until 1984 have the participant's names blacked out. Other minutes have entire paragraphs blacked out, making it impossible to know what the group was discussing. Newspaper accounts and letters written to BAR during this 17-year period indicate that various activities were taking place during this time, so it does not appear that the group was dormant. The lack of 17 years of minutes is problematic in that the petitioner has given no explanation as to whether they were lost, stolen, or destroyed. If minutes were not kept during this time, the petitioner has not explained why. The petitioner should include as many copies of ASHAI minutes as it has, or include an explanation as to why the information is unavailable. Further, the group should also submit uncensored copies of the 1978 to 1984 records.
The petition also contains copies of the council minutes, but they are likewise incomplete. Copies of minutes were submitted for 1976 to 1984, and then from 1996 to 2005, a total of 17 years. However, no minutes were submitted for 1985 to 1996, a period of 11 years. As is the case for the ASHAI minutes, there is no explanation given for the absence of these minutes. Some minutes also indicate that sign-in sheets were attached to the minutes, but these were not included in the petition. As with the ASHAI minutes, the group should submit any additional minutes, and explain the absence of the other records.
Participation in SSA Elections
Article IV of the group's current constitution (ratified in 1996) provides for the election of a council. Few of the minutes contain actual vote tallies, particularly in the period after 1997. (86.)
85. Although the group submitted ASHAI minutes from two 1977 meetings and two 1978 meetings, the list of the ASHAI board of directors ( 1975-1984) submitted by the petitioner contains no list of directors for either 1977 or 1978 (ASHAI 1984.00.00, 1-2).
86. Minutes submitted between 1977 and 1984 have large amounts of information blacked out and do riot appear to contain any references to elections; there are no minutes for the period from' 1985 to 1996. References to elections held during that period of time are taken from newspaper accounts.
Other minutes submitted by the group also show that participation by group members in elections is low.
The low rate of participation in the group's elections demonstrates that a bilateral relationship between the group's leadership and the broader membership does not exist. The lack of many years' worth of minutes and the redaction of others also makes it extremely difficult to tell who attended meetings, what issues were discussed, and whether leadership actions reflected the concerns of the whole group. The lack of sign-in sheets for many of the minutes also makes it impossible to know if the people attending were drawn broadly from a number of families across the membership, or if they constituted only a narrow portion of the membership. The petitioner should submit more evidence demonstrating that the programs and issues addressed by the leadership are actually important to the group as a whole.
The Role of the St. Francis Family
Without doubt, the single most active family among the group's membership since the 1970's has been (and continues to be) the St. Francis family. The St. Francis family's presence in Swanton dates to the 1860's when Mitchell St. Francis (1841-1918) moved to Swanton from
During the formation of the petitioner's organization in the early 1970's, Mitchell's great-grandson Homer St. Francis (1935-2001) became the most outspoken and confrontational member of the group, eventually becoming "Grand Chief." He was the group's first "Chief" and served from 1977 until 1980, when he was sentenced to jail after being convicted for breaching the peace. He was defeated in subsequent elections by Leonard "Blackie" Lampman (19221987), a man from another large Swanton family, and was narrowly re-elected to the position in 1987 after Lampman's death (Daley 1987.09.13). In 1995, he led a successful drive to change the group's constitution to make the position of "Chief' a lifetime appointment limited to members of his family, a move that many in the group disagreed with and which contributed to a split within the group (Walsh 1995.11.07) (87.) When he became too ill to handle the daily responsibilities of the group, he named his daughter "Acting Chief" and then became the "Grand Chief." He remained in this position until his death in 2002, and his daughter April (St. Francis) Merrill currently serves as "Chief." Two of St. Francis's sons served on the group's governing body with their father and sister for many years, as did a number of nieces and nephews.
St. Francis was not without his critics, both inside and outside the group. A newspaper report from 1979 indicates that there was already some splintering of the group, with the formation of the (seemingly short-lived) "Missisquoi Band" after a disputed election in which allegations of ballot-tampering were made (Abbey 1979.00.00:1). According to the article, St. Francis's "authoritarian style" and his disregard for the opinions of others led to the formation of the breakaway group. This would not be the last time that a portion of the group split away from the main body nor would it be the last time that St. Francis's leadership was cited as the reason. Nevertheless, he inspired fierce loyalty in many members, who appreciated his aggressiveness in pursuing various claims against the State of Vermont. St. Francis was often described as "militant" (New York Times 1987.09.13) when dealing with the larger community, and made various threats against local residents and authorities, including threatening to set fire to the home of the State's attorney for Franklin County (New York Times 1988.10.02). He proposed actions such as issuing the group's own license plates, and claimed jurisdiction over the Missisquoi Wildlife Reserve. He was also active in the "fish-ins" field by the group in the 1970s and 1980s to protest State fishing and hunting licensing requirements for SSA members. (88.) His
87. Approximately 70 former SSA members formed the "Traditional Abenaki of Mazipskwik and Related Bands" in 1995, in response to what they considered the "dictatorial" attitude of Homer St. Francis and the monopolization of the group by his family members (Anonymous 1995.10.30). This group has not petitioned for Federal acknowledgment.
88. Wiseman claims that the first "fish-in" took place on April 19, 1974 (Wiseman 2001, 154), but no documentation included in the petition contains information about that event. The first date given for a "fish-in" within the submitted documentation is 1979.
The Role of the Lampman Family
In the years between 1980 and 1986, Leonard "Blackie" Lampman (1922-1987) served as the group's "chief" and on the ASHAI board of directors. The Lampman's were, like the St. Francises, a large family with roots in the area going back to the late l9th century. "Blackie" Lampman was not as confrontational as Homer St. Francis, and under his leadership, the group began to pursue social and educational opportunities, as well as preparing its petition for Federal acknowledgment. (89.)
After Lampman's death in 1986, his son Lester Lampman lost an election to Homer St. Francis by three votes, 144-141 (Daley 1987.09.13, 1)." This close election was contested, but St. Francis refused to hold another election. Bank accounts for ASHAI were frozen because local banks were unable to determine who had the authority to make decisions for the group (Daley 1988.01.07). A judge ordered that the ASHAI board of directors hold another election, and 298 members voted, electing a slate of candidates supportive of St. Francis (Daley 1988.01.11). The Lampman family was largely removed from positions of authority, although some members did serve on the group's council. In 1995, the group revised its constitution to make St. Francis leader for life, essentially keeping the position of "chief' within the St. Francis family. (91.)
After the mid-1990's, the Lampman family's role is less clear. There is some indication that a few members remained involved with the group, but minutes provided by the group also suggest there was considerable friction between the group in power (many of whom were St. Francis supporters) and those who backed the Lampman family. Wiseman indicates that some Lampman family members were involved with the Missisquol Health Center and the Title V Indian Education Office during the late 1990's, but no other information about participation in the group has been included in the submission (Wiseman 2001, 185). Minutes from one 1998 meeting show that several members of the family attended a meeting and at least one stated her Louise May (nee: Lampman)Larivee intention (as well as that of her family members) to withdraw from the group (SSA 1998.04.19, 2). At the same meeting, some members moved to have this person and her "supporters" removed from the group's rolls, although the minutes did not include the names of the people to
89. Wiseman maintains that the group established a Section 8 Low-Income Housing project called "Abenaki Acres" in 1982 (Wiseman 2001, 159). However, minutes submitted from ASHAI and the Council from 1981 and 1982 include no mention of "Abenaki Acres," and there are no newspaper articles discussing the establishment of the Housing project. The petitioner should include more specific information regarding the development of this project.
90. The 1982 petition narrative indicated that the petitioner had 935 adult members, presumably all eligible to vote.
91. According to Wiseman, at least two Lampman family members on the council signed the ratification of the constitution (Wiseman 2001, 170); however, the petition includes no council minutes between 1984 and February 1996. All vote totals reported have been taken from contemporary newspaper reports.
Political Issues Involving the SSA
Although the group did not formally organize until the 1970's, it immediately confronted the State, particularly regarding hunting and fishing rights. The group engaged in at least three "fish-ins," in 1979, 1983, and 1987. This last fish-in resulted in a court case, in which the State court ruled that, although "Indian Country" did not exist in Vermont, aboriginal hunting and fishing rights had not been relinquished (Vermont District Court 1989.00.00). (93.) However, a subsequent decision ruled that all aboriginal title in Vermont had been extinguished when the territory became a state (Vermont Supreme Court 1992.06.12). Afterwards, the group's leaders continued to deliberate further pursuing land claims action, but the petition submission contains no indication that any were filed.
In addition to the "fish-ins," the group also made other political statements. For a time, the group issued its own license plates, in defiance of State licensing laws. Some members reportedly used these plates without incident, while others are reported to have had their cars impounded or otherwise suffered police harassment (Wiseman 2001, 163). The group should submit documentation, such as police records, demonstrating which members took part in this action and who may have been targeted by the police. The group also made a claim to the land at the Missisquoi Wildlife Refuge (St. Francis 1988.06.13), and staged patrols there during the Federal Government shutdown in 1995 (Indian Country Today 1995.11.23 Refuge). Details of these actions, such as the names of those who participated, might demonstrated the ability "...to mobilize significant numbers of members and significant resources for group purposes," as defined under criterion 83.7(c)(1)(i). The petitioner is encouraged to submit any additional information regarding these events, including additional interviews with people who took part in these political actions. Documentation, such as sign-in sheets from the particular actions, would also demonstrate who was taking part in these activities.
The petitioner should submit an analysis of member participation to demonstrate that decisions being made by the group's council actually show a bilateral relationship between the leadership and the members. The group should demonstrate that the issues deemed important by the council were also important to the membership as a whole, and that the leadership is responsive to the concerns of the members. Information such as attendance lists from meetings, lists of participants in events such as the "fish-ins," and a list of those who attended the wildlife refuge "patrols" during the governmental shut-down might be helpful in determining who was participating in actions promoted by the leadership.
92. Although text in the minutes indicates that a sign-in sheet had been filled out at the meeting, it was not included in the petition submission.
93. In the prosecution of this case, the assistant Attorney General (AG) of the State requested the group's membership roll from the BAR, the precursor to the present SOFA (Eschew 1988.09.22, 1). BAR provided this roll to Vermont because it was requested by a State in the prosecution of a criminal charge (Elbert 1988.10.19, 1). At SSA's request (St. Francis 1989.01.11), BAR returned the roll and certain other documents to the group, but stressed that these documents should be resubmitted as soon as possible (Johnson 1989.02.23, 1). For more information on this series of events, see the Administrative History.
The available evidence does not demonstrate the current petitioner or its claimed ancestral family lines descended socially as a group from any Western Abenakl tribe either in Quebec or Vermont. Thus, evidence of political activity from Western Abenaki chiefs like Grey Lock and Joseph-Louis Gill (or the unknown "chiefs" identified as the late husband of a widow named "Charlotte") during the colonial period does not demonstrate political influence among the group's claimed ancestors. The petitioner has not provided evidence of what its to exercise political influence before specific claimed ancestors were doing as a group to exercise political influence 1800 and is encouraged to do so. The evidence presented for the 19th century is also inadequate. The petitioner has not submitted evidence to demonstrate what its claimed ancestors were doing as a group from 1800 to 1875 to exercise political influenced or authority. For the period from 1875 to 1900, the petitioner has presented insufficient evidence to demonstrate that Nazaire St. Frances and Cordelia (Freemore) Brow served as informal leaders of a community of its claimed ancestors. The petitioner is encouraged to review the requirements of criterion 83.7 (c) and to submit evidence that its claimed ancestors maintained political influence or authority over each other- as an autonomous entity during this period.
For the first 75 years of the 20th century, the petitioner has presented little evidence demonstrating informal leadership among any group of the petitioner's claimed ancestors. Information describing Nazaire St. Francis, Jr., 'Gene' Cote, and Cordelia (Freemore) Brow as informal leaders must be supplemented with additional information if the petitioner wishes to substantiate its claims. To satisfy the criterion, the petitioner must submit more evidence of an individual's influence over members of the population; further, the petitioner must demonstrate that his or her authority extend, beyond members of his or her immediate (and even extended) family. The petitioner may also wish to provide additional information regarding the political activities of the group as they related to the Vermont Eugenics Survey or to the land claims of the Iroquois. The petitioner is encouraged to seek any information on relationships between the people whom petitioner identifies as leaders and external authorities such as law enforcement officers and school officials, which may provide additional insight into political relationships among the petitioner's claimed ancestors. The petitioner has not demonstrated informal or formal political authority among the group or its claimed ancestors at any time before 1975, and therefore it does not satisfy the requirement for 83.7(c) for this time period.
During the 1970s, the SSA became an active political organization. Under the leadership of Homer St. Francis and Leonard Lampman, the group began its petition for Federal acknowledgment, instituted some social and cultural programs, and engaged the State in a number of legal battles. However, the petition lacks evidence to demonstrate that participation in the group's political processes was widespread across the membership of the group. The lack of sign-in sheets and named participants is especially problematic because it is impossible to demonstrate who exactly was involved in the group's various meetings. Further, the lack of 17 years of ASHAI minutes and 11 years of council meetings (and the submission of redacted ASHAI and council minutes spanning 8 and 9 years respectively) also makes it difficult to understand what issues were important to the group and who was participating in the group's political organization. The petitioner has not demonstrated that the organization formed after 1975 has a bilateral relationship between the membership and the elected (or appointed)
To rectify these deficiencies, the petitioner should include copies of the documents cited m the finding, Including the missing minutes, sign-in sheets, and lists of participants in activities such as the "fish-ins." The group should also submit other documentation, such as interviews, which describe issues of importance to the group, including discussions of conflict (particularly during the years for which the petitioner has not submitted any meeting minutes), and how those issues were addressed or resolved. There should also be, to the extent possible, an effort to link membership to participation in group political activities.