During the American Indian Wars, the American Army carried out a number of massacres and forced relocations of Indigenous peoples, acts that some scholars say constitute genocide. The Sand Creek Massacre, which caused outrage in its own time, has been called genocide. General John Chivington led a 700-man force of Colorado Territory militia in a massacre of 70–163 peaceful Cheyenne and Arapaho, about two-thirds of whom were women, children, and infants.