The court ruled that it was filed too late under the applicable statute of limitations — NAGPRA requires that lawsuits be filed within a certain period of the discovery of the claimed violation, and the court found that the applicable period had run.

The dismissal did not resolve the underlying question of where Geronimo’s remains are.

It resolved only the specific legal mechanism through which the descendants sought to answer that question.

The mystery remained open.

Geronimo’s Life And The Apache Resistance: Historical Context

To understand why the question of Geronimo’s remains matters as much as it does, you have to understand what Geronimo represented — and what the Apache resistance of the late nineteenth century was about.

The Chiricahua Apache had lived in the mountain country of what is now southeastern Arizona, southwestern New Mexico, and the adjacent areas of northern Mexico for generations.