That term of art is inscribed on a plaque found at a memorial to the Bear River Massacre located just a few miles north of Preston, Idaho.

"The Battle of Bear River was fought in this vicinity January 29, 1863," the official inscription lies, using the expression "battle" to describe an incident that is more honestly depicted as state-authorized mass murder. The attack was carried out because Shoshones gathered in the village had been designated, without due process, or even a perfunctory effort to provide evidence, as "guilty of hostile attacks on settlers and immigrants."