IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

CASE NO.: ______________

TREVOR L. CARPENTER, Chief of the Global First Nations, Plaintiff,

v.

GEORGE W. BUSH, NICK ROCKEFELLER, and YALE UNIVERSITY, Defendants.

________________________________________________/

COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF, DAMAGES, AND REPATRIATION OF HUMAN REMAINS

I. INTRODUCTION

1. This is a civil action brought by Plaintiff Trevor L. Carpenter, Chief of the Global First Nations, to correct a century-old injustice: the desecration, theft, and illicit retention of the mortal remains of the Apache leader known as Geronimo (Goyaałé).
2. The Plaintiff alleges that the Defendants, or organizations under their control or influence, are in wrongful possession of the skull, femur, and other skeletal remains of Geronimo, which were illegally disinterred from a grave at Fort Sill, Oklahoma, in approximately 1918.
3. Plaintiff seeks the immediate repatriation of these remains under the Native American Graves Protection and Repatriation Act (NAGPRA), common law property rights, and international human rights standards regarding indigenous sovereignty.

II. PARTIES

4. Plaintiff, TREVOR L. CARPENTER, is the Chief of the Global First Nations. He brings this suit on behalf of the lineage of Geronimo and the collective spiritual and cultural rights of First Nations people globally.
5. Defendant, GEORGE W. BUSH, is a private citizen and former President of the United States. He is sued in his capacity as a prominent member of the Order of Skull and Bones (The Russell Trust Association), an unincorporated association operating on the campus of Yale University.
6. Defendant, NICK ROCKEFELLER, is sued as a private citizen alleged to exercise influence and control over the assets and secrets associated with the aforementioned Order and the illicit collection of indigenous artifacts.
7. Defendant, YALE UNIVERSITY, is a private university located in New Haven, Connecticut. The University provides the physical grounds for the “High Street Tomb” where the remains are alleged to be sequestered.

III. JURISDICTION AND VENUE

8. This Court has subject matter jurisdiction pursuant to 28 U.S.C. § 1331 (Federal Question) as this action arises under the laws of the United States, specifically the Native American Graves Protection and Repatriation Act (NAGPRA), 25 U.S.C. § 3001 et seq.
9. Venue is proper in this district as the Defendants transact significant business here, and the political implications of the withholding of these remains affect national policy regarding indigenous rights.

IV. FACTUAL ALLEGATIONS

10. Geronimo, a spiritual and military leader of the Apache, died as a prisoner of war at Fort Sill, Oklahoma, in 1909.
11. Upon information and belief, in or around May 1918, Prescott Bush (grandfather of Defendant George W. Bush) and other members of the Skull and Bones society serving as Army volunteers at Fort Sill, conspired to dig up the grave of Geronimo.
12. It is alleged that the skull, two femurs, and various bits of tack (bridle gear) were removed from the grave and transported to New Haven, Connecticut.
13. These remains were placed within the “Tomb,” the windowless headquarters of the Skull and Bones society on the campus of Defendant Yale University.
14. Evidence of this theft includes a discovered letter dated 1918 from a society member detailing the exhumation: “The skull of the worthy Geronimo the Terrible, exhumed from its tomb at Fort Sill by your club… is now safe inside the Tomb.”
15. Defendants Bush and Rockefeller, by virtue of their membership and high status within the organization, maintain constructive possession and control over these remains.
16. Despite repeated demands from Apache descendants and First Nations representatives, Defendants have refused to return the remains or allow for an independent DNA audit of the contents of the High Street Tomb.

V. CAUSES OF ACTION

COUNT I: VIOLATION OF NAGPRA (25 U.S.C. § 3001 et seq.) 17. Plaintiff repeats and realleges the foregoing paragraphs. 18. The remains of Geronimo constitute “Native American cultural items” and “human remains” under the Act. 19. Defendant Yale University, as a recipient of federal funds, acts as a museum/repository under the definition of the Act. 20. Defendants have failed to inventory and repatriate these remains to the lineal descendants or the appropriate First Nations authorities represented by the Plaintiff.

COUNT II: CONVERSION 21. Plaintiff has a superior right to possession of the ancestral remains. 22. Defendants have intentionally exercised dominion and control over the remains in a manner inconsistent with the Plaintiff’s rights. 23. This conversion is ongoing and continuous, as the remains are used for alleged rituals within the High Street Tomb.

COUNT III: INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS 24. The act of keeping the skull of a revered indigenous leader as a trophy or ritual object is extreme and outrageous conduct. 25. Defendants know, or should know, that such conduct causes severe emotional distress to the Plaintiff and the First Nations community.

COUNT IV: UNJUST ENRICHMENT 26. Defendants have unjustly enriched themselves by enhancing the mystique, notoriety, and recruitment power of their organization through the possession of these stolen historical remains.

VI. PRAYER FOR RELIEF

WHEREFORE, Plaintiff Trevor L. Carpenter prays for judgment against Defendants as follows:

A. A Declaration that the remains currently held in the Skull and Bones Tomb are those of Geronimo; B. An Order requiring Defendants to immediately surrender the remains to the Plaintiff for proper burial according to traditional customs; C. An Order granting Plaintiff access to the High Street Tomb to inspect and catalog any other indigenous artifacts or remains; D. Compensatory and Punitive damages in an amount to be determined at trial for the century of desecration and emotional distress; E. For costs of suit, reasonable attorney’s fees, and such other relief as the Court deems just and proper.

DEMAND FOR JURY TRIAL Plaintiff hereby demands a trial by jury on all issues so triable.

DATED: November 24, 2025

Respectfully submitted,

/s/ Mike Jukic

Mike Jukic, Esq. Lead Counsel AXISLAW.SITE Attorney for Plaintiff Trevor L. Carpenter, Chief of the Global First Nations