**As long as the category exists on Wikipedia, it applies to Leonard Peltier.  It's a matter of public record.  He's a convicted killer, regardless of what some people think.  For example, even though most people believe O.J. Simpson is a murderer, it would violate Wikipedia rules to add the "American murderer" category to him because he was never convicted.  However, Peltier was convicted and has never had a successful appeal to date.