text:  The controversy attracted increased academic attention to Churchill 's research , which had already been criticized by the legal scholar John <unk> and historian Guenter Lewy . Additional critics were the sociologist Thomas Brown , who had been preparing an article on Churchill 's work , and the historians R.G. Robertson and Russell Thornton , who claimed that Churchill had misrepresented their work . In 2005 , University of Colorado Boulder administrators ordered an investigation into seven allegations of research misconduct , including three allegations of plagiarism , and four allegations of fabrication or falsification regarding the history of the Dawes Act , the Indian Arts and Crafts Act of 1990 , and statements that smallpox was intentionally spread to Native Americans by John Smith in 1614 and by the United States Army at Fort Clark in 1837 ( not to be confused with the well @-@ documented use of smallpox @-@ infected blankets at Fort Pitt in 1764 ) . 
  