The oldest reference I have to a tune called "Cripple Creek" is from the "Owingsville [Ky.] Outlook" in 1905, when it was played in an old fiddlers' contest.

Other pre-1915 mentions come from Virginia and North Carolina, also as an "old-time" or "backwoods" tune.

That strongly suggests that Cripple Creek in Virginia is that of the title.

The creek itself is mentioned in the Philadelphia Inquirer as early as 1796, but there's no way to know just how old the tune or the title is.

To be an "old fiddler" in 1905, I'd say you'd most likely have learned your repertoire in the 1860s, '70s, or '80s. It's so simple a tune (a little like "Twinkle, Twinkle, Little Star" [1760s]) it could have developed decades before the Civil War.

More than that, who can say?