noncombatants, including women, children, and prisoners, whether in the context of a battle or otherwise"). Displacement and disruption Throughout history, Indigenous people have been subjected to the repeated and forced removal from their land. Beginning in the 1830s, there was the relocation of an estimated 100,000 Indigenous people in the United States called the “Trail of Tears". The tribes affected by this specific removal were the Five Civilized Tribes: The Cherokee, Creek, Chickasaw, Choctaw, and Seminole. The treaty of New Echota, was enacted, which stated that the United States “would give Cherokee land west of the Mississippi in exchange for $5,000,000”. According to Jeffrey Ostler, "Of the 80,000 Native people who were forced west from 1830 into the 1850s, between 12,000 and 17,000 perished." Ostler states that "the large majority died of interrelated factors of starvation, exposure and disease". In addition to the removal of the Southern Tribes, there were multiple other removals of Northern Tribes also known as "Trails of Tears." For example, "In the free labor states of the North, federal and state officials, supported by farmers, speculators and business interests, evicted Shawnees, Delawares, Senecas, Potawatomis, Miamis, Wyandots, Ho-Chunks, Ojibwes, Sauks and Meskwakis." These Nations were moved West of the Mississippi into what is now known as Eastern Kansas, and numbered 17,000 on arrival. According to Ostler, "by 1860, their numbers had been cut in half" due to low fertility, high infant mortality, and increased disease caused by conditions such as polluted drinking water, few resources, and social stress. Ostler also writes that the areas that Northern tribes were removed to were already inhabited: "The areas west of the Mississippi River were home to other Indigenous nations— Osages, Kanzas, Omahas, Ioways, Otoes and Missourias. To make room for thousands of people from the East, the government dispossessed these nations of much their lands." Ostler writes that in 1840, when Northern Nations were moved onto their land, "The combined population of these western nations was 9,000 ... 20 years later, it had fallen to 6,000." Later apologies by government officials On 8 September 2000, the head of the United States Bureau of Indian Affairs (BIA) formally apologized for the agency's participation in the ethnic cleansing of Western tribes. In a speech before representatives of Native American peoples in June 2019, California governor Gavin Newsom apologized for the "California Genocide." Newsom said, "That’s what it was, a genocide. No other