Following years of non-Indian encroachment on their land, some Sioux tribes lashed out in a war known as the Sioux Uprising. Defeated, the Sioux were expelled from their homeland in Minnesota. The Santee Sioux were relocated to the Niobrara Nebraska reservation, but the tribe had no secure title to the land.

The Santee Sioux attempted unsuccessfully to negotiate a treaty to guarantee their reservation. Alternatively, some sought to gain title through the Homestead Act of 1862. The act was open to any citizen or intended citizen, including many minorities, but not Native Americans. Nonetheless some Santee Sioux successfully obtained a homestead, but most lived in uncertainty on their land until the reservation was individually allotted under the Dawes Act of 1887.