McClanahan v. Arizona State Tax Commission
McClanahan v. Arizona State Tax Comm'n, 411 U.S. 164 (1973), was a case in which the Supreme Court of the United States holding that Arizona has no jurisdiction to impose a tax on the income of Navajo Indians residing on the Navajo Reservation and whose income is wholly derived from reservation sources.[1]
| McClanahan v. Arizona State Tax Comm'n | |
|---|---|
 | |
| Argued December 12, 1972 Decided March 27, 1973 | |
| Full case name | McClanahan v. Arizona State Tax Commission |
| Citations | 411 U.S. 164 (more) 93 S. Ct. 1257; 36 L. Ed. 2d 129; 1973 U.S. LEXIS 89 |
| Case history | |
| Prior | McClanahan v. State Tax Commission, 484 P.2d 221 (Ariz. App. Div. 1 1971). |
| Holding | |
| Arizona has no jurisdiction to impose a tax on the income of Navajo Indians residing on the Navajo Reservation and whose income is wholly derived from reservation sources. | |
| Court membership | |
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| Case opinion | |
| Majority | Marshall, joined by unanimous |
| Laws applied | |
| Treaty with the Navajo Indians, 15 Stat. 667; Buck Act, 4 U.S.C. § 104 et seq.; Ariz. Rev. Stat. Ann. §43-102(a) | |
Background
Rosalind McClanahan was an enrolled member of the Navajo Nation in Arizona. In 1967, all of her income came from work on the Navajo Reservation; $16.20 was withheld from her wages. She requested a refund of the entire amount and protested the collection of state taxes. When the state declined her claim, she filed an action in the Arizona Superior Court. The court dismissed her case for failure to state a claim. McClanahan appealed to the Arizona Court of Appeals, which affirmed. The Arizona Supreme Court declined to hear the case, and the United States Supreme Court granted certiorari to hear the case.[1]
Decision
Justice Thurgood Marshall delivered the opinion of a unanimous court. Marshall found that there was nothing in federal law that authorized Arizona to collect a state income tax from an Indian that earned the income on the reservation. The case was reversed.[1]
External links
- Text of McClanahan v. Arizonza State Tax Comm'n, 411 U.S. 164 (1973) is available from: CourtListener Findlaw Google Scholar Justia Library of Congress Oyez (oral argument audio)