Challenges Ahead: Recognition and Sovereignty Issues Face by the Haudenosaunee Nationals Lacrosse Team on Their Path To the 2028 Olympics

By: Mallory Brown*                                                                        Posted: 02/05/2024

Introduction

In 2028, lacrosse will return to the Olympics.[1] However, the sport’s creators may be prevented from playing.[2] To allow the Haudenosaunee Nationals to play in 2028, both the United States and the International Olympic Committee (“IOC”) must take steps to affirm their recognition of the Haudenosaunee Confederacy as a sovereign nation.[3]

A History of Lacrosse and the Haudenosaunee

Canadian French for ‘hooked stick,’ lacrosse was created by indigenous communities in the Great Lakes, Mid-Atlantic, and American South. [4]  While there were several regional variations in how lacrosse was played, modern lacrosse is most similar to the game developed by the Haudenosaunee Confederacy.[5]  The Haudenosaunee Confederacy, called the Iroquois by the French and the League of Five Nations by the English, includes the Mohawks, Oneidas, Onondagas, Cayugas, and Senecas. [6] The Haudenosaunee Confederacy refers to lacrosse as the creator’s game and is represented by a team called the Haudenosaunee Nationals.[7]

Past Challenges for Haudenosaunee Nationals

The Haudenosaunee Nationals are well-regarded; they are ranked third out of forty-six teams and seventy international lacrosse federations. [8] Despite their success, they have faced considerable challenges competing at international lacrosse championships.[9] In both 2010 and 2022, the Haudenosaunee Nationals were told that, despite qualifying, they could not play international lacrosse championships.[10]

In 2010, the Haudenosaunee Nationals traveled to New York’s John F. Kennedy International Airport, having qualified to play in the World Lacrosse Championship.[11] As a team representing a sovereign nation, the Haudenosaunee Confederacy, the Haudenosaunee Nationals presented their Haudenosaunee passports.[12] Because they intended to travel on their Haudenosaunee passports and not American passports, the United Kingdom refused to grant visas.[13] After spending days in New York, Secretary of State Hillary Clinton granted them a one time travel allowance to go to Manchester, England; however, the team bowed out, refusing to be prevented from using their own passports.[14] To many, this incident illustrated the sovereignty and recognition issues faced by indigenous nations. [15] Then, in 2022, the Haudenosaunee Nationals were again almost prevented from playing in an international competition. [16]

Internationally, lacrosse is governed by the World Lacrosse Organization.[17]  However, the International World Games Association (“IWGA”) organizes the lacrosse World Games.[18] In 2022, IWGA cited concerns that the Haudenosaunee Nationals do not represent a sovereign nation as justification for excluding them from the World Games in Birmingham, Alabama.[19] Consequently, the Irish National team dropped out of the World Games to allow the Haudenosaunee Nationals to play. [20] However, questions about the Olympic eligibility persist.[21]

Olympic Eligibility

For Olympic eligibility, the IOC, the governing body for the Olympics, requires countries to be “recognized by the international community.”[22] Typically, the IOC recognizes sovereignty based on the United Nations (“UN”) membership status from the UN’s founding in 1947. [23] However, this requirement has posed a persistent problem for indigenous communities, which may be sovereign nations within the boundaries of other countries, such as the United States, Canada, and Australia.[24]

Sovereignty and Haudenosaunee Passports

In the United States, the legal interactions between tribal nations and local, state, and federal governments represent a complex overlay of national and international law, treaties, and court decisions. [25] Each tribe has an independent relationship with the United States determined by historic, and often one-sided, negotiations.[26]  For the Haudenosaunee Confederacy, this relationship has been characterized by a few key interactions.[27] In 1924, the United States Congress passed the Indian Citizenship Act, which gave indigenous peoples United States citizenship.[28] However, the Haudenosaunee Confederacy strongly objected to the Act, noting that they were not consulted in the passage of the act, nor did they agree with its basic idea—that the Haudenosaunee Confederacy was not an independent nation. [29] The rejection of the Indian Citizenship Act illustrates a central tension between the United States and the Haudenosaunee Confederacy, and a tension which is at the heart of the Haudenosaunee Nationals challenges: the status of the Haudenosaunee Confederacy as an independent nation. [30]

The Haudenosaunee Confederacy cites the 1794 Treaty of Canandaigua between the Haudenosaunee and the United States as a central document of sovereignty. [31] The treaty recognized the Haudenosaunee Confederacy's territorial boundaries and their status as an independent nation. [32] On this basis, the Haudenosaunee Confederacy sues for land claims, enforces treaty terms, and issues passports.[33]

While the Haudenosaunee Confederacy began issuing passports in 1977, after September 11, 2001, travel restrictions, particularly those involving passports, changed.[34]  The United States adopted the Western Hemisphere Travel Initiative, which required travelers to present passports at the United States and Mexican border and the United States and Canadian border, ignoring the reality that sovereign tribal lands span the border.[35] Similar issues arose during the 2010 World Lacrosse Games, illustrating the multitude of recognition challenges the Haudenosaunee Nationals may face trying to compete in the 2028 Olympics.[36]

Proposals for 2028

Both the United States and the IOC should make efforts to include the Haudenosaunee Nationals in the 2028 Olympics, a process in which recognition will be key.[37] The United States should engage in bilateral agreements with Canada to formally establish Haudenosaunee rights, recognize and support the use of Haudenosaunee passports by working to provide consular services and affirm a national commitment to Haudenosaunee sovereignty. [38] In tandem, the IOC should work to provide the Haudenosaunee a pathway to recognition, and to address the inequities between recognized and unrecognized countries.[39]

The United States, in recognition of its legal commitments to Haudenosaunee sovereignty, should engage in domestic and foreign rule-making and agreements to reaffirm that recognition and, thereby, bolster international recognition of Haudenosaunee sovereignty. [40]As the Haudenosaunee lands span the United States/Canadian border both countries should consult with the Haudenosaunee to harmonize their regulations of tribal lands and set out clear declarations of sovereignty.[41] This would bolster international understanding of the complex tribal and federal interactions in North America, and allow the Haudenosaunee to point to these declarations as evidence of international recognition. [42] As another step, the United States should support the Haudenosaunee’s rights of self-determination by assisting in their use of Haudenosaunee passports. [43] By doing so, the United States would bolster the international community’s perception of these passports, especially in a security conscious post-9/11 world and help display to the IOC that the Haudenosaunee do in fact regulate their internal affairs. [44] Ultimately, the spotty recognition of the Haudenosaunee by the United States, and the international community, is the result of a troubled history and a lack of federal investment in its commitments to the Haudenosaunee. [45] With work, the United States can work toward solutions — solutions which could go a long way with the IOC. [46]

While the IOC has a long history of excluding certain nationals or separatist regions, it has made some progress, and it can build on this progress for the Haudenosaunee in 2028 .[47] For example, Puerto Rico, Hong Kong, South Sudan, and representatives from Afghanistan have all participated in the Olympics despite their unrecognized status. [48] The IOC could recognize the Haudenosaunee on a similar basis to its recognition of Puerto Rico.[49]

Like Puerto Rico, which elects its own government, but also functions within the United States’ federal legal and political system, the Haudenosaunee are governed by councils and operate their own internal affairs departments. [50] The IOC could also recognize the Haudenosaunee based on the same criteria they recognized Kosovo in 2014: recognition by other international sporting bodies. [51] The Haudenosaunee could rely on World Lacrosse and the IWGA to bolster their application for a National Olympic Committee. [52]

Alternatively, the IOC could look to the United Nations Declaration on the Rights of Indigenous Peoples or United States/Canadian interactions with the Haudenosaunee as a basis for granting a National Olympic Committee. [53]] The Haudenosaunee have applied for a committee in the past and are renewing their application for 2028. [54] By including the Haudenosaunee’s national game in the 2028 Olympics, the IOC took its first major step toward a Haudenosaunee National Olympic Committee, and now the IOC needs to see that the Haudenosaunee are represented in Los Angeles in 2028.[55]

Conclusion

While complex and marred by history, the sovereignty and recognition issues that have posed a challenge to the Haudenosaunee Nationals are solvable. [56] With work, over the next four years, the IOC and the United States can make reforms to allow the Haudenosaunee Nationals to play in 2024. [57] Further this work requires that the United States re-affirm its existing commitments and that the United States and IOC recognize the work and contributions of the Haudenosaunee. [58] As Peter Milliman said in 2022, “What kind of competition would you have in lacrosse if the first nation to ever play, and still one of the best, isn’t represented?” [59]

*Staff Writer, Jeffrey S. Moorad Sports Law Journal, J.D. Candidate, May 2025, Villanova

[1] See Lacrosse to Return to the Olympics, World Lacrosse (Oct. 16, 2023), https://worldlacrosse.sport/article/lacrosse-to-return-to-the-olympic-games-in-2028/ (announcing lacrosse’s return to Olympic games in 2028); see also Lacrosse: Top Things to Know, Olympics (Oct. 13, 2023) https://olympics.com/en/news/lacrosse-rules-players-origins-things-to-know (noting lacrosse appeared at Olympics in 1904 and 1908 and demonstrations were played in 1928, 1932, and 1948); see also Lacrosse to Return to the Olympic Games In 2028, World Lacrosse, (Oct. 16, 2023), https://worldlacrosse.sport/article/lacrosse-to-return-to-the-olympic-games-in-2028/ (discussing lacrosse’s enduring popularity in North American and rapid increase in popularity in recent years around the world which allows international and Olympic recognition).

[2] See Victor Mather, Lacrosse Is Coming to the Olympics. Will Its Inventors Be There?, N.Y. Times (Oct. 19, 2023), https://www.nytimes.com/2023/10/19/sports/olympics/lacrosse-2028-olympics-haudenosaunee.html (recounting concerns about recognition preventing Haudenosaunee Nationals from representing Haudenosaunee Confederacy for lacrosse in 2028 Olympics).

[3] See Candace Maracle, Haudenosaunee Nationals a Step Closer To Being In the Olympics With Inclusion of Lacrosse, CBC (Oct. 16, 2023), https://www.cbc.ca/news/indigenous/haudenosaunee-nationals-olympics-lacrosse-1.6997921 (describing hope for Haudenosaunee to play in 2028 Olympics because IOC admitted lacrosse as event). Additionally, the article quotes First Nations director of Lacrosse Canada: “There's still a lot of work to do that must take place by I.O.C. and its membership and everyone else who will grant us the status to play and compete in the Olympics.” See id. (adding that Nationals are regarded as leaders in lacrosse and often held other countries establish their own teams).

[4] See Lacrosse, Online Etymology Dictionary https://www.etymonline.com/word/lacrosse (last visited Nov. 10, 2023) (describing etymology of word “lacrosse” and noting “the native name is represented by the Ojibwa (Algonquian) verb ‘baaga'adowe’ ‘to play lacrosse.’”); see Lacrosse History, USA Lacrosse https://www.usalacrosse.com/lacrosse-history (last visited Nov. 10, 2023) (describing regional variation of lacrosse and its development across North America during pre-colonial period).

[5] See Noelle E. C. Evans, An Indigenous Lacrosse Team Reclaims Its Native Identity, NPR (June 26, 2023), https://www.npr.org/2023/06/26/1184104966/an-indigenous-lacrosse-team-reclaims-its-native-identity (reporting on Haudenosaunee participation in World Lacrosse Championships and emphasizing their ties to lacrosse as creators of modern game).

[6] See Who We Are, Haudenosaunee Confederacy, https://www.haudenosauneeconfederacy.com/who-we-are/ (last visited Nov. 11, 2023) (describing history of Haudenosaunee Confederacy and non-native names given to it by French and English).

[7] See Why We Changed Our Name, Haudenosaunee Nationals, https://haudenosauneenationals.com/pages/about-haudenosaunee-nationals-lacrosse (last visited Nov. 12, 2023) (noting name changed from Iroquois Nationals to Haudenosaunee Nationals because word “Iroquois” is derogatory in French for word snake); see Haudenosaunee or Iroquois?, New York State Museum, https://www.nysm.nysed.gov/education/videos/haudenosaunee-or-iroquois (last visited Nov. 19, 2023) (explaining Haudenosaunee means “people of the long house,” while Iroquois is a colonist name with which Haudenosaunee do not identify).

[8] See Josh Kron, Gaming the System, Foreign Policy (Aug. 22, 2023), https://foreignpolicy.com/2021/08/22/iroquois-nationals-haudenosaunee-confederacy-lacrosse-los-angeles-olympics-2028-indigenous-sovereignty-canada-united-states/#cookie_message_anchor (describing how Haudenosaunee developed modern lacrosse and how successful its lacrosse team has been in national and international games).

[9] See Thomas Kaplan, Iroquois Lacrosse Team Misses Game in England, N.Y. Times (July 15, 2010) https://www.nytimes.com/2010/07/16/us/16iroquoisweb.html?searchResultPosition=3 (reporting that Haudenosaunee Nationals missed game against England due to passport dispute).

[10] See id. (describing 2010 incident in which Haudenosaunee Nationals arrived in New York to fly to international championships and were told they would not be allowed to travel on their Haudenosaunee passports); see Samantha Pope, More Than Just a Game: Iroquois Nationals Fight For Inclusion in The 2022 World Games, Canadian Geographic (Aug. 11, 2020), https://canadiangeographic.ca/articles/more-than-just-a-game-iroquois-nationals-fight-for-inclusion-in-the-2022-world-games/ (recounting Haudenosaunee Nationals being told they would not be permitted to compete in 2022 World Games).

[11] See Mike McAndrew, Iroquois Nationals Team Stuck In New York Another Day Despite US Waivers on Passport Dispute, Syracuse.com (July 14, 2010), https://www.syracuse.com/news/2010/07/us_agrees_to_let_us_born_membe.html (describing confusion over Haudenosaunee Nationals arrival in New York and refusal to let them travel to England).

[12] See Kaplan, supra note 9 (explaining Haudenosaunee Nationals wanted to travel on their national passports because they viewed using their United States passports as rejection of Haudenosaunee status as sovereign nation).

[13] See Ewen MacAskill, Iroquois Lacrosse Team Caught In a Cleft Stick Over Passports, The Guardian (July 13, 2010), https://www.theguardian.com/world/2010/jul/13/iroquois-lacrosse-passport-world-cup (reporting on blame shifting between United States and United Kingdom for why lacrosse team was not permitted to travel).

[14] See Michelle Chen, Passport Flap Keeps Iroquois Out of World Lacrosse Championships, Colorlines (July 17, 2010), https://colorlines.com/article/passport-flap-keeps-iroquois-out-world-lacrosse-championships/ (explaining State Department offered one time solution to passport issue). The article also interviews Haudenosaunee Nationals team members who felt that the issues at stake were greater than sports and amounted to the sovereign recognition challenges faced by the Haudenosaunee nation for almost three hundred years. See id. (characterizing team’s choice not to play, despite one time visa, reflected their unyielding commitment to their nations sovereignty).

[15] See id. (quoting Indigenous Law Institute’s Steven Newcomb “the Haudenosaunee right to travel to and from their home territory is an ancestral birthright, a fundamental right, and an international human right”).

[16] See Ka’nhehsí:io Deer, Iroquois Nationals Lacrosse Team To Compete In 2022 World Games After Initial Exclusion, CBC (Sept. 9, 2020) https://www.cbc.ca/news/indigenous/iroquois-nationals-lacrosse-world-games-1.5717395 (reporting on Haudenosaunee Nationals’ near exclusion from World Games in 2022 because they were not eligible under IOC rules, although it was unclear why World Games believed they were ineligible).

[17] See Inside WL, World Lacrosse https://worldlacrosse.sport/about/ (last visited Nov. 11, 2023) (noting that IOC recognizes World Lacrosse as that sport’s governing body).

[18] See Lacrosse, The World Games https://www.theworldgames.org/sports/Lacrosse-54 (last visited Nov. 11, 2023) (explaining lacrosse has been member of International World Games Association since 2013 and crediting Haudenosaunee for their contributions to lacrosse).

[19] See Deer, supra note 16 (describing explanation given to Haudenosaunee Nationals about why they were barred from competing based on their non-recognition by IOC).

[20] See Bo Hamby, Ireland Lacrosse Bows Out Of 2022 World Games So Iroquois Nationals Can Play, NPR (Oct. 1, 2020) https://www.npr.org/2020/10/01/917033527/ireland-lacrosse-bows-out-of-2022-world-games-so-iroquois-nationals-can-play (quoting Irish player “None of us would be going to Birmingham, Ala., in the first place if it wasn't for the Iroquois and giving us the gift of their medicine game”).

[21] See Kron, supra note 8 (recounting fears that Haudenosaunee Nationals will be ineligible for 2028 Olympics).

[22] See Int’l Olympic Comm., Olympic Charter, at 66 (July 17, 2020), https://stillmed.olympic.org/media/Document%20Library/OlympicOrg/General/EN-Olympic-Charter.pdf  (defining country and establishing process for recognizing countries to found National Olympic Committees); see National Olympic Committees, Int’l Olympic Comm., (Nov. 13, 2023), https://olympics.com/ioc/national-olympic-committees (noting IOC is only entity empowered to recognize National Olympic Committees and countries must form such committees to be eligible for Olympics); see also Eddie Pells, Lacrosse At the Olympics Gives Indigenous Communities a Chance To See Their Sport Shine, USA Today (Oct. 19, 2023), https://www.usatoday.com/story/sports/olympics/2023/10/19/lacrosse-at-the-olympics-gives-indigenous-communities-a-chance-to-see-their-sport-shine/71240810007/ (reporting that National Olympic Committee requirement may prevent Haudenosaunee from competing because they have historically limited sovereign recognition).

[23] See Kron, supra note 8 (describing IOC’s process for sovereign recognition).

[24] See Matthew Williams, How Do Indigenous Athletes Fit into the Olympics?, JSTOR Daily (Aug. 7, 2021), https://daily.jstor.org/how-do-indigenous-athletes-fit-into-the-olympics/ (describing how Olympics’ definition of nations often excludes indigenous populations).

[25] See Nicole Terese Capton Marques, Comment, Divided We Stand: The Haudenosaunee, Their Passport and Legal Implications of Their Recognition in Canada and the United States, 13 San Diego Int'l L.J. 383, 389-95 (2011) (describing various sources of law which define tribal and federal relationships both in United States and Canada).

[26] See Frequently Asked Questions, United States Department of the Interior Indian Affairs, https://www.bia.gov/frequently-asked-questions#:~:text=Tribes%20possess%20all%20powers%20of,inconsistent%20with%20overriding%20national%20policies. (last visited Nov. 12, 2023) (describing process and history of federal government’s recognition of indigenous tribes).

[27] See Brian Doyle, Let Them Play: Reestablishing Iroquois Tribal Passports, 45 Suffolk Transnat'l L. Rev. 421, 426-28 (2012) (describing important court cases, legislation and treaties which have defined United States and Haudenosaunee relationship). Under U.S. law, indigenous tribes are considered “domestic dependent states,” a classification which recognizes their independence but still holds that U.S. law is supreme. See id. (noting that this classification led to losses in sovereign rights as tribes were not treated like foreign nations).

[28] See Indian Citizenship Act of 1924, Pub. L. No. 68-175, 43 Stat. 253 (1924); see also Rebecca Tsosie, The Politics of Inclusion: Indigenous Peoples and U.S. Citizenship, 63 UCLA L. Rev. 1692, 1700-1701 (2016) (noting pushback against Indian Citizenship Act because it represented proposition that, for indigenous communities, citizenship came from statute, not American Constitution).

[29] See Doyle, supra note 27, at 426-28 (noting that Haudenosaunee Confederacy decline citizenship because they see themselves as sovereign nation).

[30] See Marques, supra note 25, at 425 (arguing recognition is critical to tribal identity and has been a central issue between Haudenosaunee and federal government).

[31] See Treaty of Canandaigua, 1794, National Museum of the American Indian, https://americanindian.si.edu/nationtonation/treaty-of-canandaigua.html (last visited Nov. 12, 2023) (noting that Treaty of Canandaigua was earliest treaty between Native Americans and United States and that George Washington signed it).

[32] See Robert Odawi Porter, Contemporary Significance of the Canandaigua Treaty, Capital Hill Policy Group (Nov. 6, 2020), https://www.capitolhillpolicygroup.com/blog/contemporary-significance-of-the-canandaigua-treaty (noting legal implications of the treaty including sovereignty and recognition of tribal lands).

[33] See G. Peter Jemison, Treaty of Canadaigua 1794: 200 Years of Treaty Relations Between the Iroquois Confederacy and the United States, N.Y. Times (2000), https://archive.nytimes.com/www.nytimes.com/books/first/j/jemison-treaty.html?scp=8&sq=Aotearoa&st=cse (describing legal basis for enforcing Treaty of Canadaigua). The author also notes, “[s]o convinced are we Haudenosaunee of our sovereignty that we issue our own passports to travel abroad, using them in countries that honor them. This writer has twice traveled to New Zealand to meet with Maori artists and others, each time with a Haudenosaunee passport. Our passports have made a great impression on the Maori people who are, of course, the aboriginal inhabitants of Aotearoa.” See id. (arguing Haudenosaunee sovereignty should be recognized by United States); see Doyle, supra note 27, at 431-32 (describing that Haudenosaunee claims to sovereignty are unique because the nation has never surrendered its independent status).

[34] See Oren R. Lyons Joagquisho, Iroquois Lacrosse Team Faces Hardships by Traveling on Their Own Passports, Cultural Survival (July 12, 2010), https://www.culturalsurvival.org/news/iroquois-lacrosse-team-faces-hardships-traveling-their-own-passports (recounting Haudenosaunee history of issuing passports and challenges faced by their lacrosse team in trying to travel on those passports).

[35] See Tim Gaynor, New Travel Rules Leave Native Americans In Limbo, Reuters (Dec. 11, 2007) https://www.reuters.com/article/lifestyle-usa-native-passports-dc/new-travel-rules-leave-native-americans-in-limbo-idUKN1163473120071212 (reporting on questions native communities had about impact of Western Hemisphere Travel Initiative on their land).

[36] See Chen, supra note 14 (highlighting sovereign recognition issues at play in 2010 passport dilemma).

[37] See Kron, supra note 8 (noting Haudenosaunee would be first unrecognized Native American nation to play in Olympic Games).

[38] See Marques, supra note 25, at 422-425 (arguing United States should work with Canada to provide consular support for Haudenosaunee passports). The author suggests that issuing tribal identification cards could help create records which would bring Haudenosaunee passports into compliance with current security standards. See id. (adding that Haudenosaunee could utilize already existing United States passport services to streamline process).

[39] See Alexander Loengarov, Medals But No Country? The Olympics and the Fuzzy Boundaries of Statehood, Fletcher Forum (Feb. 20, 2022), https://www.fletcherforum.org/home/2022/2/20/medals-but-no-country-the-olympics-and-the-fuzzy-boundaries-of-statehood (noting statehood is fluid concept which IOC often allows National Committees for countries with limited recognition). The author adds, by way of example, that only three of the fourteen United Kingdom overseas territories have national committees, which often raises questions of unequal treatment. See id. (adding Gibraltar sued IOC for National Committee recognition).

[40] See Marques, supra note 25, at 418-420 (describing how United States collaboration with Haudenosaunee and Canadian governments could result in ‘mutual recognition’ given complex history and border disputes).

[41] See Marques, supra note 25, at 417-18 (arguing United States and Canadian cooperation could clarify some uncertainty about where Haudenosaunee govern, where United States governs and where Canada governs).

[42] See Marques, supra note 25, at 419-20 (suggesting United States and Canada need to reconsider their regulations and working on “trans-border cooperation” would legitimize international recognition of Haudenosaunee passports). Additionally, the author argues that setting out clear bilateral cooperation agreements would keep these issues from being decided solely by courts. See id. (adding bilateral agreements would be strong starting place for dealing with these issues).

[43] See Marques, supra note 25, at 422-23 (arguing United States and Canadian passport services being used for Haudenosaunee passports would be formal acknowledgement of legitimacy of those passports).

[44] See Marques, supra note 25, at 422-23 (adding United States and Canadian passport support would alleviate security concerns about Haudenosaunee passports).

[45] See Doyle, supra note 27, at 422-25 (tracing court decisions and legislation which rejected Haudenosaunee sovereignty, despite Haudenosaunee treaties and Indian Commerce Clause). The author notes that the Indian Commerce Clause treats Native Americans as foreign nations which displays a legislative intent for the tribes to be treated as sovereign. See id. (describing ambiguous court decisions which have clouded true meaning of Clause).

[46] See Doyle, supra note 27, at 445-50 (suggesting three models for Haudenosaunee-United States relations). The author advocates for working within the existing domestic dependent state model in which some foreign relations functions are delegated to the United States and others, such as issuing passports remain with the Haudenosaunee. See id. (suggesting this middle ground is achievable and will result in harmony between United States and Haudenosaunee).

[47] See Jeron Heijman, Unrecognized States at the Olympics, Olympstats (Nov. 4, 2014) https://olympstats.com/2014/11/04/unrecognized-states-at-the-olympics/ (describing IOC’s decision to allow Kosovo, as breakaway nation, to compete in Olympics but noting Kosovo had previous Olympic history).

[48] See Kron, supra note 8 (listing Olympic teams which represent unrecognized states, including Puerto Rico, American Samoa, U.S. Virgin Islands, British Virgin Islands, and Hong Kong).

[49] See Rob Bedeaux, Why Does Puerto Rico Have its Own Olympic Team?, Sports Engine (Dec. 20, 2021), https://www.sportsengine.com/olympics/why-does-puerto-rico-have-its-own-olympic-team (noting Puerto Rico’s IOC recognition is based in part on fact that Puerto Rico governs its own internal affairs).

[50] See Government, Haudenosaunee Confederacy, https://www.haudenosauneeconfederacy.com/government/ (last visited Nov. 19, 2023) (describing governmental structure of Confederacy and providing information about development, environmental and documents committees).

[51] See Ryan Gauthier, Statehood and the Olympic Games, 114 Am. J. of Int’l L. 380, 381, 383 (2020) (describing role of other international sporting bodies in convicting IOC to admit Kosovo on that basis instead of political recognition).

[52] See e.g., Haudenosaunee Claim Bronze With Emphatic Win, World Lacrosse (July 1, 2023) https://worldlacrosse.sport/article/haudenosaunee-claim-bronze-with-emphatic-win/ (providing play-by-play of Haudenosaunee wins over Australia, Japan, England, and Hong Kong at World Championship).

[53] See Marques, supra note 25, at 409-18 (connecting UN Declaration to need to recognize Haudenosaunee sovereign passports because it espouses importance of national self-determination).

[54] See Kron, supra note 8 (reporting Haudenosaunee are forming a National Olympic Committee and revisiting their application for UN member status).

[55] See Matt Kinnear, 'Our Gift to the World': Haudenosaunee Optimistic, Hopeful For Olympic Inclusion, Inside Lacrosse (Oct. 18, 2023) https://www.insidelacrosse.com/article/-our-gift-to-the-world-haudenosaunee-optimistic-hopeful-for-olympic-inclusion/62173 (describing Haudenosaunee hope that IOC will be repetitive to inclusion because it elected to admit lacrosse as Olympic sport).

[56] See Marques, supra note 25, at 420-25 (providing structural and legal solutions to passport recognition issues).

[57] See Eben Novy-Williams, LA28 Boss Casey Wasserman Talks MLB Players, Indigenous Lacrosse Team, Sportico (Oct. 13, 2023) https://www.sportico.com/leagues/baseball/2023/la28-olympics-mlb-haudenosaunee-1234742028/ (interviewing 2028 Olympic chairman who expressed hope that IOC could find solution to allow Haudenosaunee to compete).

[58] See Marques, supra note 25, at 425 (noting much of legal groundwork for sovereign cooperation has been laid and international countries need only recognize it).

[59] See Mather, supra note 2 (adding Haudenosaunee Nationals would likely qualify for Olympics, if they are permitted to try).