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 if their income is wholly derived from reservation sources.

McClanahan v. Arizona State Tax Comm'n
Supreme Court of the United States
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
Chief Justice Warren E. Burger Associate Justices William O. Douglas · William J. Brennan Jr. Potter Stewart · Byron White Thurgood Marshall · Harry Blackmun Lewis F. Powell Jr. · William Rehnquist
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.

Decision

Justice Thurgood Marshall delivered the opinion of a unanimous court. He 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.

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)