McClanahan v. Arizona State Tax Commission explained

Litigants:McClanahan v. Arizona State Tax Comm'n
Arguedate:December 12
Argueyear:1972
Decidedate:March 27
Decideyear:1973
Fullname:McClanahan v. Arizona State Tax Commission
Usvol:411
Uspage:164
Parallelcitations:93 S. Ct. 1257; 36 L. Ed. 2d 129; 1973 U.S. LEXIS 89
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.
Majority:Marshall
Joinmajority:unanimous
Lawsapplied:Treaty with the Navajo Indians, ; Buck Act, et seq.; Ariz. Rev. Stat. Ann. ยง43-102(a)

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.[1]

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.

Notes and References

  1. McClanahan v. Arizonza State Tax Comm'n,