''Chickasaw Nation v. United States'', 534 U.S. 84 (2001),. was a case in which the

Supreme Court of the United States The Supreme Court of the United States (SCOTUS) is the highest court in the federal judiciary of the United States. It has ultimate appellate jurisdiction over all U.S. federal court cases, and over state court cases that involve a point o ...

held that Indian tribes were liable for taxes on gambling operations under 25 U.S.C. §§ 2701–2721.

Indian Gaming Regulatory Act The Indian Gaming Regulatory Act (, ''et seq.'') is a 1988 United States federal law that establishes the jurisdictional framework that governs Indian gaming. There was no federal gaming structure before this act. The stated purposes of the act ...

, .

Background

The Chickasaw Nation operated several business, and used a pull-tab, similar to a scratch-off lottery ticket, to generate revenue for the tribe. The

Internal Revenue Service The Internal Revenue Service (IRS) is the revenue service for the United States federal government, which is responsible for collecting U.S. federal taxes and administering the Internal Revenue Code, the main body of the federal statutory ta ...

(IRS) advised the tribe that the tribe owed excise taxes and federal occupational taxes on revenue generated from the sales of these pull-tabs to the public. The tribe paid the amount sought by the IRS and then filed a claim for reimbursement, averring that the tribe was exempt from such taxes under the provisions of

(IGRA), . The United States denied the claim, and the tribe filed suit in the Federal District Court, Eastern District of Oklahoma.''Chickasaw Nation v. United States'', No. 97-CV-511-P (E.D. Okla. 1998) The court granted the government's motion for summary judgment and the tribe appealed. The Tenth Circuit Court of Appeals affirmed the decision of the trial court and the tribe appealed. The

Supreme Court A supreme court is the highest court within the hierarchy of courts in most legal jurisdictions. Other descriptions for such courts include court of last resort, apex court, and high (or final) court of appeal. Broadly speaking, the decisions of ...

granted

certiorari In law, ''certiorari'' is a court process to seek judicial review of a decision of a lower court or government agency. ''Certiorari'' comes from the name of an English prerogative writ, issued by a superior court to direct that the record of ...

.. Additionally, the Choctaw Nation used the same pull-tab system and also filed suit in Federal District Court,''Choctaw Nation of Okla. v. United States'', No. 97-CV-510-B (E.D. Okla. 1998) with the same results as the Chickasaw tribe, and at the Tenth Circuit. At the Supreme Court, the appeals were combined.

Opinion of the Court

Justice

Stephen Breyer Stephen Gerald Breyer ( ; born August 15, 1938) is a retired American lawyer and jurist who served as an associate justice of the U.S. Supreme Court from 1994 until his retirement in 2022. He was nominated by President Bill Clinton, and repl ...

delivered the opinion of the Court, affirming the judgment of the lower courts. The tribes argued that they were exempt from such taxes due to a provision of the IGRA that indicated that the tax laws applied to tribes in the same manner as to the states, which did not have to pay such taxes. The Court held that this was not the case, despite information in the record of the acts authors that stated that the "tax treatment of wagers conducted by tribal governments be the same as that for wagers conducted by state governments..." The court held that the tribes were liable for the taxes.

Dissent

Justice

Sandra Day O'Connor Sandra Day O'Connor (born March 26, 1930) is an American retired attorney and politician who served as the first female associate justice of the Supreme Court of the United States from 1981 to 2006. She was both the first woman nominated and th ...

dissented, joined by Justice David Souter. O'Connor pointed out that the standard statutory construction involving Indian tribes require that "statutes are to be construed liberally in favor of the Indians, with ambiguous provisions interpreted to their benefit."''Montana v. Blackfeet Tribe of Indians'', She argued that the Court did not do so in this case.

References

External links

*
Official Website of the Chickasaw Nation
{{DEFAULTSORT:Chickasaw Nation V. United States United States Supreme Court cases United States Supreme Court cases of the Rehnquist Court United States Native American gaming case law United States Native American tax case law Chickasaw Nation Choctaw 2001 in United States case law Native American history of Oklahoma