Who Owes Whom an Apology? Spain, Mexico, and the American Mirror We Keep Avoiding

Who Owes Whom an Apology?

Spain, Mexico, and the American Mirror We Keep Avoiding

By a regulated optimist who grades with a pencil, votes with both hands, and still believes maps should tell the truth.

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I. Opening the Wrong Door

In the year of our political disquiet, Mexico's new president, Claudia Sheinbaum, revived an old quarrel: Spain should apologize for the conquest. Madrid demurred. The press dutifully recorded the choreography—letters not answered, inaugurations uninvited, ministries "perplexed"—and the spectacle faded into the next spectacle. But the door we keep opening is the wrong one. If apologies are a currency, they must purchase something besides headlines. And if history is the bill of sale, the United States cannot watch this exchange without checking its own ledger.

A sober timeline: in 2019, President Andrés Manuel López Obrador asked Spain and the Pope to apologize for the conquest; Madrid refused on grounds you've heard before—we don't judge the 16th century by 21st-century standards. In 2021, Pope Francis acknowledged "very painful errors" by the Church in Mexico's past, an ecclesial register of contrition that did not bind Spain's government. In 2024–25, Sheinbaum renewed the ask and escalated the symbolism. Spain again said no. That's the surface. The substratum is a question about models of empire, and how different colonial grammars produce different modern deficits.

Before we pronounce sentence on anyone else's remorse, we should ask what an apology is for. I propose a minimalist ethic: an apology should unlock specific repairs that only acknowledgment can enable. If it cannot do that work, it is penitence as pageantry.

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II. Two Colonialisms, Two Ledgers

There is no clean empire. Still, not all colonialisms are organized the same way. Political theorist Patrick Wolfe carved the distinction precariously into the desk: settler colonialism aims to eliminate and replace; extractive/imperial colonialism aims to dominate and incorporate. The Anglo-American experience tilted hard toward the former—remove the people, allot the land, forget the language. The Iberian experience mixed domination and incorporation—repúblicas de indios, caste hierarchies, mission towns; grim coercions alongside legal fictions that nonetheless constrained some abuses and preserved corporate Indigenous communities. Both projects birthed horrors; their afterlives differ.

The United States legislated removal (1830), allotment (1887), and forced assimilation through boarding schools (19th–20th centuries). It later apologized, sometimes sotto voce, after the damage calcified into demography. The record is not ambiguous: statecraft as cultural erasure.

Spanish America legislated an elaborate, contradictory code—Leyes de Burgos (1512–13) and New Laws (1542)—that named Indigenous peoples "free vassals of the Crown," even as encomienda, repartimiento, and debt peonage ground bodies into silver and wheat. The code did not save lives on the scale disease and mines destroyed; it did create forums and fictions that Indigenous communities sometimes used to defend land and custom. To teach this is not to absolve the lash; it is to describe the shape of the fence.

The Spanish "republics of Indians"—towns with their own councils (cabildos), communal lands, and litigation strategies—were hardly egalitarian. Yet they left behind archives in Nahuatl, Mixtec, Quechua, and Spanish that still argue back. That juridical dualism preserved collective legal subjects in ways the United States, with its ruthless individual allotment and later termination policies, worked to obliterate. Again: different wounds; different scars.

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III. Language as Census of Conscience

Languages are the weather of memory. In Mexico today, about 6.1% of people over age three—7.36 million—speak one of 68 national Indigenous languages comprising roughly 364 variants, and the state recognizes those languages in law. In the United States, Native North American language use continues to decline (about 342,000 speakers across dozens of languages), despite late-in-the-day policy pivots to protect them. Numbers are not morality plays, but they are trails of policy.

Why the divergence? Part is demography: densely settled Mesoamerica and the Andes maintained Indigenous majorities well into the colonial centuries; North America's Eastern Woodlands faced catastrophic disease, warfare, removal, and a settler state with demographic momentum. Part is law: Mexico's 2003 General Law on the Linguistic Rights of Indigenous Peoples and constitutional Article 2 recognize collective rights and languages as national; the U.S. Native American Languages Act (1990) repudiated suppression but cannot unwind a century of punishment for speaking one's mother tongue.

None of this excuses Iberian conquest or the Church's complicities. It simply names a relative preservation that Spanish legal pluralism, missionary philology, and corporate community status helped to extend—even as Bourbon reforms later pushed Hispanicization. (Philip II once decreed Nahuatl an administrative bridge; Charles III later tried to smother Indigenous languages officially. Bureaucracies rarely speak with one mouth.)

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IV. Books, Bells, and Ledgers

A partial syllabus for grown-ups:

• David J. Weber, The Spanish Frontier in North America—frontiers as negotiations, not lines.
• Andrés Reséndez, The Other Slavery—Indigenous bondage beyond the courtroom's gaze; indispensable for breaking the halo.
• Oxford Research Encyclopedia entries on Spanish–Indigenous jurisdictions—how pueblos de indios litigated and lived within Iberian law.
• The Laws of Burgos / New Laws—primary texts to feel the Crown's self-congratulation and constraint in the same clause.
• The Florentine Codex—Nahua voices in Nahuatl and Spanish, a doubled mirror to the Conquest and a reminder that Indigenous intellectuals wrote back.

Read them and you cannot sustain either propaganda—the crimson legend or the whitewash.

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V. The American Mirror

Now we turn the glass toward home. The Indian Removal Act (1830), the Dawes Act (1887), and the federal boarding-school project were not accidental misdemeanors. They were a philosophy: If we cannot possess the land with them, we will possess it without them; if we cannot erase them by exile, we will try by education. President Biden's 2024 boarding-school apology—real and overdue—acknowledged as much, echoing a quiet 2009 Congressional apology buried in a defense bill. The apologies matter, but only if they buy us policy: language revitalization, land and water settlements honored, and the end of performative consultations.

And if the United States were to pass judgment on others' contrition, it should do so after finishing its own. (As a matter of constitutional hygiene, sweep your courtroom before lecturing the neighbors.)

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VI. What Spain Owes; What Mexico Needs; What the U.S. Should Learn

Does Spain "owe" Mexico an apology? As a moral matter, apologies for historical atrocities are neither absurd nor trivial. The Vatican has modeled versions of contrition that do not concede history to caricature. Madrid could, without surrendering to anachronism, say: We regret the violence done under our flags and crosses; we honor the peoples who survived. It would cost little and buy some grace. Spain's refusal sits less on jurisprudence than on domestic politics.

What should the United States learn? Two things:

1. Plural legal forms can preserve communities that a homogeneous civil code dissolves. Spain's dualist fiction—república de españoles / república de indios—could be cruel; it was also a scaffold for survival. The U.S., allergic to corporate Indigenous personality save where treaties force it, could study why Mexico still counts millions of Indigenous language speakers while we fight to keep hundreds of thousands.

2. Apologies without administrative reform are theater. The United States' apology timeline is longer than its implementation timeline. Expand the programs that work: immersion schooling, tribally run justice systems, and rights-of-way processes that require tribal consent rather than performatively invite it. (A true apology changes procurement.)

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VII. Why the "Spain vs. Mexico" Frame Misses the Mark

From a U.S. vantage, the argument is not Spain vs. Mexico but stories we tell about colonialism vs. the institutions we build in its wake.

• Integration is not absolution. Spanish America braided peoples through marriage, baptism, markets, and municipal law; that braid included a racialized casta regime that formalized hierarchy. The Anglo-American variant often sought removal, then assimilation by force. If Indigenous languages and community corporations persisted more widely in the former, it is not because the conquest was kind; it is because power incorporated as well as exploited. If they faded more catastrophically in the latter, it is not because the settlers were blunt; it is because the project was replacement. Different poisons; different symptoms.

• Archives are not alibis. Iberian law's paper trail—cabildo petitions, land grants, bilingual catechisms—is sometimes mistaken for compassion. It is better read as governance that knew it needed Indigenous labor and legitimacy, and so built channels that, at times, protected both. Those channels are why a farmer in Oaxaca can still litigate in Mixe; why a water committee in New Mexico calls its foreman a mayordomo; why a municipal clerk in the Sierra Norte can point to a 17th-century title and say, "Here is our fence."

• The ledger of death remains. Any defense of "integration" that forgets epidemic collapse, forced labor, and mission coercion is not history but romance. Read Reséndez and the archives of Potosí and tell me again about benevolence. The task is not to rank atrocities but to understand institutional afterlives so that our repairs are tailored, not ritual.

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VIII. What an Adult Apology Might Do

Suppose Madrid says the words. What then?

1. Joint Language Fund. Spain and Mexico commit a decade of funding for co-produced documentation and revitalization of Indigenous languages (Mexico's 68 and diaspora languages in Spain's immigrant communities). Link it to digitization, teacher training, and municipal services, not just libraries. This is penance as infrastructure.

2. Archive Without Borders. A shared platform—call it El Archivo—combining Mexican municipal/colonial records and Spanish archives with full-text search in Spanish + Indigenous languages, built on open APIs so that tribes, ejidos, and town councils can actually use it in land and water claims. (The Florentine Codex digitization shows the path; now generalize it.)

3. Legal Clinics for Communal Lands. Fund bilateral clinical programs in Mexican law schools to defend comunidades indígenas and ejidos, drawing on the very pluralism the empire left behind. Use Spanish endowments to bankroll them; use Mexican sovereignty to steer them.

4. Teach the Two Ledgers. Spain acknowledges its role in coercion and evangelization; Mexico teaches that many criollo and indio elites co-produced colonial order. Ambivalence is not treason; it is adult pedagogy.

These are the kinds of outcomes an apology should purchase. Anything less is a press conference.

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IX. The U.S., Again: No Standing to Smirk

A last look inward. While Mexico and Spain argue about the 16th century, the U.S. Census tells us that Native language use here continues to decline, and that our premier strategy for preventing that decline—boarding schools—required a formal apology in 2024 because the 2009 apology was whispered into a defense appropriations bill. If you want to know whether a republic is serious, check which truths it speaks out loud and which it buries in Section 8113.

So by all means, offer Madrid your opinion of decorum. Then fund immersion preschools and tribal radio and court interpreters for Navajo, Yupik, Cherokee, and the rest, and you will have spoken the only apology that counts.

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X. Three Short Scenes (for Scale)

1. Mexico City, Zócalo, 2025. Sheinbaum marks the 500th year since Cuauhtémoc's death, and a school choir sings in Nahuatl and Spanish. The cameras want the line about Spain; the microphones catch the kids. A grandmother mouths the Nahuatl syllables she was never taught in school. The point has already been made.

2. Saint Augustine, Florida. A ranger explains that the city is older than Jamestown by decades, and a family looks startled, then pleased, then curious. A boy asks whether anyone ever apologized to the Timucua. The ranger hesitates. The silence is honest—which is a start. (The city's coquina walls outlast our rhetoric.)

3. Window Rock, Arizona. A tribal radio host switches from Diné bizaad to English and back, on air, and reminds listeners where to pick up free children's books printed in Navajo orthography. This is what survival sounds like: verbs doing the work apologies pretend to do.

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XI. Verdict, Such as It Is

Spain can apologize without rewriting the cosmos; Mexico can accept without outsourcing its dignity; the United States can watch and, perhaps, learn how to replace ceremony with structure. The conquest was conquest. But it left two Americas inside one hemisphere: an Anglo project that often sought elimination and an Iberian project that often sought incorporation. Where we are generous, we admit both proved violent and both left institutions that can be hacked for justice.

If apologies are to mean anything, they should be keys—keys that open archives, fund classrooms, hire interpreters, and let communities speak, in their own languages, about what they want next.

And if we must keep asking who owes whom, the adult answer is: we all do, and the debt is payable in schools, water, courts, and the stubborn tenderness of bilingual forms.

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Notes & Sources (selected)

• Spain–Mexico "apology" dispute and Sheinbaum's 2024–25 posture; Spain's refusals.
• Pope Francis's 2021 letter acknowledging "very painful errors."
• U.S. Indian Removal (1830), Dawes Act (1887), boarding-school reports and apologies (2009, 2024).
• Patrick Wolfe on settler colonialism's logic of elimination.
• Laws of Burgos (1512–13), New Laws (1542): Indigenous as free vassals; limits on enslavement (imperfectly enforced).
• Oxford Research Encyclopedia on Spanish–Indigenous jurisdictions; pueblos de indios.
• Andrés Reséndez, The Other Slavery (2016) for the coercion that persisted outside formal law.
• Mexico's Indigenous language policy & counts (Article 2; INALI; 68 languages/364 variants; ~7.36M speakers).
• U.S. decline in Native language use (ACS 2017–2021).
• Nahuatl as administrative and literary language in early New Spain; Florentine Codex.
• David J. Weber, The Spanish Frontier in North America (1992).
• Biden's 2024 apology for boarding schools; 2009 Congressional apology (Defense Appropriations Act, Section 8113).