McClanahan v. Arizona State Tax Commission

What happened

The appellant in this case was an enrolled member of the Navajo tribe who lived on the part of the Navajo Reservation located within Arizona. All of her income came from reservation sources. Arizona applied its personal income tax to her. She sued, and the trial court dismissed her complaint. The Arizona Court of Appeals affirmed, citing Williams v. Lee (1959) to hold that the test was whether the tax infringed the Navajo tribe's right to be self-governing, not whether it infringed her rights as an individual.

The Supreme Court unanimously reversed, in an opinion by Justice Marshall. It described the problem as one of reconciling the plenary power of the States over residents within their borders with the semi-autonomous status of Indians living on tribal reservations. The Court pointed to an agreement the government entered with the Navajo Nation in 1868. It provided that a prescribed reservation would be set aside "for the use and occupation of the Navajo tribe of Indians."

The Court held that "by imposing the tax in question on this appellant, the State has interfered with matters which the relevant treaty and statutes leave to the exclusive province of the Federal Government and the Indians themselves." The tax was unlawful as applied to reservation Indians with income derived wholly from reservation sources.

Three years later, in Bryan v. Itasca County (1976), the Court cited McClanahan in deciding that Public Law 280 did not authorize states to tax reservation Indians.

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