Native American conflicts with settlers arose due to competing uses of land for hunting versus farming, as well as differing views of land ownership between individual settlers and communal Native American tribes. Two notable conflicts were the Sand Creek Massacre, where Colonel Chivington slaughtered 200 Cheyenne despite a promise of safety, and the Battle of Little Big Horn, where General Custer and his troops were surrounded and killed by Lakota and Cheyenne warriors he had tried to surprise.