Eliza Burton “Lyda” Conley was born around 1868 to Eliza Burton Zane Conley, a member of the Wyandot tribe, and Andrew Conley, an English farmer in Kansas. Conley was one of four sisters. Conley attended the Kansas City School of Law and graduated as one of the only women in her class. She was admitted to the Missouri Bar in 1902 and the Kansas Bar in 1910. Conley also trained as a telegraphic operator, taught at Spalding Business College in Kansas City, and taught Sunday school at her church.

Lyda Conley is best known for her efforts to protect the Huron Indian Cemetery, the resting ground of her parents and Wyandot ancestors, and for being the first Native American woman to argue before the Supreme Court. The Huron Cemetery is located in the heart of downtown Kansas City, Kansas. As the city grew, the cemetery was repeatedly threatened by commercial development. Situated so close to the business district, the cemetery had become valuable commercial property and numerous attempts were made to sell the sacred ground.

In 1906, Congress approved legislation to sell the land occupied by the cemetery and move the bodies to the nearby Quindaro Cemetery. Conley filed a permanent injunction against the U.S. Secretary of the Interior and Indian Commissioners in U.S. District Court to prevent the sale. Conley and her sister Helena built a shack, known as “Fort Conley,” at the entrance to the cemetery. As her lawsuit went through the courts, Conley and her sister took up residence in Fort Conley, with their shotgun, and guarded their family and ancestors’ graves day in and day out.   

Lyda Conley eventually took her case to prevent the sale of the cemetery to the Supreme Court. Although it was ultimately dismissed, Conley’s case and passionate defense of the cemetery attracted national attention and support from local lawmakers. In 1912, Senator Charles Curtis introduced a bill in congress to preclude the sale of the cemetery. In the decades after Lyda Conley’s death, several more attempts were made to sell the land, but the cemetery had become known and appreciated as a local historic landmark and no buyers materialized. In 1971 the cemetery was placed on the National Register of Historic Places and in 2017 it received Historic Landmark status and was officially renamed the Wyandotte National Burying Ground.

Conley died in 1946 after she was attacked on her way home from the library. She is buried, next to her family, in the Wyandotte National Burying Ground. 

Learn more about Lyda Conley and her sisters in the Kansas Room.