During the early 1890s, Wyoming passed a state law prohibiting the killing of elk for their teeth, which led to the arrests of several Bannock hunters in 1895.

In response, the United States Army launched an expedition into the area- when troops arrived, it was found that the situation was peaceful and that the fears of uprising were unjustified.

Elk was a main food source for the Bannocks, who lived on Fort Hall Reservation across the border in Idaho, and whose treaty guaranteed a right to hunt "unoccupied lands."

Once news of the incident reached the public, exaggerated reports made their way to the East Coast, where a New York newspaper claimed that all of the settlers in Jackson's Hole had been massacred by the Bannocks.

The headline on July 27 of the Maryland newspaper "Baltimore Morning Herald" read: "Butchered by Bannocks - An Awful Massacre at Jackson's Hole.

In an earlier article the "Baltimore Morning Herald" stated that their source, a mail carrier from Star Valley, said that the Bannocks had blocked off the passes leading into Jackson Hole and that the residents within the area were all fleeing for their lives.

In the subsequent investigation, the United States Indian Service arranged for a test case regarding the Bannocks' treaty-reserved off-reservation hunting rights.