Residential and commercial development was a driving force in the desecration of many Native American burial sites, particularly in the 20th century with the expansion of suburbs and urban sprawl. For example, in Wana the Bear v. Community Construction (1982), two-hundred Miwok ancestral remains were bulldozed in the development of a residential area in Stockton, California. A descendant of the people, Wana the Bear, attempted to prevent further desecration by arguing that the site should continue to be protected as a cemetery. However, the California Court of Appeals sided with the construction company, which finished in its destruction of the burial grounds for residential development.
