My response:
One, the dwellings on the right look like they're made of bark, not fabric. That might qualify them as wigwams, not tipis.
Two, I think we have to be leery of any photographic evidence. By the time photography came around in the late 19th century, tribes had been contaminated by a couple hundred years of European contact.
The best evidence would be drawings, paintings, or reports from an initial-contact situation. Anything after that becomes a record of a culture in transition.
Another factor is that this is exactly when the Plains Indians became well-known and popular. A tribe catering to visiting tourists might've adopted tipis to impress them. Or a tribe newly dependent on the government might've received tipis as an agency's idea of "Indian housing."
DMarks adds:
For some recent stereotypical uses of tipis, see Review of Apache vs. Gladiator, "Tardicaca Indians" in South Park, and Rapacious Cavalrymen in Family Guy.
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