MCCLANAHAN v. ARIZONA STATE TAX COMMISSION

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Case Basics
Docket No. 
71-834
Appellee 
Rosalind McClanahan
Appellant 
Arizona State Tax Commission
Advocates
(argued the cause for the appellant)
(argued the cause for the United States as amicus curiae urging reversal)
(Assistant Attorney General of Arizona, argued the cause for appellee)
Tags
Term:
Facts of the Case 

Rosalind McClanahan was a member of the Navajo Indian nation who lived on the Navajo Reservation in Apache County, Arizona. Her employer withheld $16.20 in 1967 for Arizona state income taxes. McClanahan sought the return of her withheld income. She claimed that since she was a Navajo Indian residing on the reservation and since her income was derived completely on the reservation, she was exempt from state taxation. When her request was denied, she filed suit in Apache County Superior Court. The Superior Court dismissed her claim. The Court of Appeals of Arizona affirmed the dismissal. The Supreme Court of Arizona rejected her petition for review.

Question 

Did the State of Arizona have a right to tax Navajo Indians residing on the Navajo Reservation if their income is entirely from reservation sources?

Conclusion 
Decision: 9 votes for Mcclanahan, 0 vote(s) against
Legal provision:

No. In a unanimous decision, the Court reversed the decision of the Arizona Court of Appeals and held that Arizona did not have the right to tax McClanahan. In an opinion authored by Justice Thurgood Marshall, the Court emphasized the long-standing status of Indian reservations as exempt from state authority. While the Navajo Treaty signed between the Navajo nation and the United States did not explicitly exempt the nation from state laws, Arizona entered the Union on the explicit condition that it would lose its authority over Indian tribes and reservations within the state, including taxation powers. Consistent with its decision in Warren Trading Post Co. v. Arizona State Tax Commission, the Court ruled that Arizona "had no jurisdiction to impose" state income tax on McLanahan.

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MCCLANAHAN v. ARIZONA STATE TAX COMMISSION. The Oyez Project at IIT Chicago-Kent College of Law. 21 June 2014. <http://www.oyez.org/cases/1970-1979/1972/1972_71_834>.
MCCLANAHAN v. ARIZONA STATE TAX COMMISSION, The Oyez Project at IIT Chicago-Kent College of Law, http://www.oyez.org/cases/1970-1979/1972/1972_71_834 (last visited June 21, 2014).
"MCCLANAHAN v. ARIZONA STATE TAX COMMISSION," The Oyez Project at IIT Chicago-Kent College of Law, accessed June 21, 2014, http://www.oyez.org/cases/1970-1979/1972/1972_71_834.