Federal Lawsuit Challenges Muscegee Nation’s Citizenship Rules for Black Creek Freedmen

Descendants of Black people enslaved by the Muscegee (Creek) Nation have filed a complaint in the U.S. District Court in Oklahoma City, seeking an order that Principal Chief David Hill and the Muscegee Nation Citizenship Board issue tribal-citizenship cards that a Muscegee Nation Supreme Court mandated in July 2025. Plaintiffs Rhonda Grayson and Jeffrey Kennedy argue that the tribe’s refusal violates the 1866 treaty that abolished slavery and granted citizenship to formerly enslaved individuals. The lawsuit contends that the board’s 2019 denial of the applications—based on an inability to locate a lineal descendant—contradicts the court’s finding that the pair are entitled to citizenship and the associated right to vote and full participation in tribal affairs.

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The 1866 treaty required the Muscegee Nation to recognize Black Creek Freedmen as citizens. In 1979 the tribe adopted a constitution that limited membership to descendants listed as “Muscogee (Creek) Indians by blood” on the Dawes Rolls, a federal census created around 1900. When the Dawes Rolls were compiled, individuals were placed on separate rolls: one for Muscogee members and another for those identified as Freedmen. The 2025 court order directs the citizenship board to apply the 1866 treaty to future applicants who can trace ancestry to either roll, potentially opening tribal citizenship to thousands of Black Creek descendants.

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Attorney Damario Solomon-Simmons, representing the plaintiffs, notes that roughly 100,000 Black Creek individuals reside across the United States. Successful litigation could create a pathway to citizenship for many who are not Muscogee by blood, mirroring recent court-ordered changes in the Seminole and Cherokee Nations that have already extended citizenship to Freedmen descendants.

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• “Every day of non-compliance is another day that Black Creek Freedman are denied our birthright and our very identity as citizens,” — Rhonda Grayson, president of the Muscogee Creek Indian Freedmen Band

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The case remains pending, and the tribe’s next procedural actions will determine whether the court’s 2025 directive is implemented, potentially reshaping citizenship criteria for the Muscegee Nation and other Oklahoma tribes.

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