Bryan v. Itasca County

What happened

Russell Bryan, an enrolled member of the Minnesota Chippewa Tribe, lived in a mobile home on land the United States holds in trust for the Chippewa Tribe on the Leech Lake Reservation. In June 1972 Itasca County sent him notices assessing a personal property tax on the mobile home. Bryan sued in state court, arguing that Minnesota and the county had no authority to tax it. Minnesota's courts rejected his claim. They read Public Law 280, a 1953 federal law, as giving the state civil jurisdiction that included taxation.

The Supreme Court unanimously reversed. Justice Brennan wrote that the "central focus" of Public Law 280 was to give states criminal jurisdiction over crimes involving Indians. The Act said nothing about authority to tax Indians or Indian property on reservations. The Court called that "a significant omission," since Congress would normally have said something if it meant a sweeping change in the status of reservation Indians.

The Court also called the civil-jurisdiction section "admittedly ambiguous" and said that ambiguous statutes passed for the benefit of Indians are construed in their favor.

Years later, in California v. Cabazon Band (1987), the Court described Bryan as reading the section to give states jurisdiction over private civil litigation involving reservation Indians in state court, but not general civil regulatory authority.

Summarized with AI assistance from 3 sources and checked against their words; not yet reviewed by historians or by the nations. Report an error