Chickasaw Nation v. United States
Encyclopedia
Chickasaw Nation v. United States, 534 U.S. 84
(2001), was a case in which the Supreme Court of the United States
held that Indian tribes were liable for taxes on gambling operations under .
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
(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 Indian Gaming Regulatory Act
(IGRA), . The United States denied the claim, and the tribe filed suit in the Federal District Court, Eastern District of Oklahoma
., 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 granted certiorari
.
Additionally, the Choctaw Nation
used the same pull-tab system and also filed suit in Federal District Court, with the same results as the Chickasaw tribe, and at the Tenth Circuit. At the Supreme Court, the appeals were combined.
delivered the opinion of the court. 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. Breyer 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.
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." The court did not do so in this case, and she respectfully dissented.
Case citation
Case citation is the system used in many countries to identify the decisions in past court cases, either in special series of books called reporters or law reports, or in a 'neutral' form which will identify a decision wherever it was reported...
(2001), was a case in which the Supreme Court of the United States
Supreme Court of the United States
The Supreme Court of the United States is the highest court in the United States. It has ultimate appellate jurisdiction over all state and federal courts, and original jurisdiction over a small range of cases...
held that Indian tribes were liable for taxes on gambling operations under .
Background
The Chickasaw NationChickasaw Nation
The Chickasaw Nation is a federally recognized Native American nation, located in Oklahoma. They are one of the members of the Five Civilized Tribes. The Five Civilized Tribes were differentiated from other Indian reservations in that they had semi-autonomous constitutional governments and...
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
Internal Revenue Service
The Internal Revenue Service is the revenue service of the United States federal government. The agency is a bureau of the Department of the Treasury, and is under the immediate direction of the Commissioner of Internal Revenue...
(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 Indian Gaming Regulatory Act
Indian Gaming Regulatory Act
The Indian Gaming Regulatory Act 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...
(IGRA), . The United States denied the claim, and the tribe filed suit in the Federal District Court, Eastern District of Oklahoma
United States District Court for the Eastern District of Oklahoma
The United States District Court for the Eastern District of Oklahoma is the Federal district court whose jurisdiction comprises the following counties: Adair, Atoka, Bryan, Carter, Cherokee, Choctaw, Coal, Haskell, Hughes, Johnston, Latimer, Le Flore, Love, Marshall, McCurtain, McIntosh, Murray,...
., The court granted the government's motion for summary judgment and the tribe appealed. The Tenth Circuit Court of Appeals
United States Court of Appeals for the Tenth Circuit
The United States Court of Appeals for the Tenth Circuit is a federal court with appellate jurisdiction over the district courts in the following districts:* District of Colorado* District of Kansas...
affirmed the decision of the trial court and the tribe appealed. The Supreme Court granted certiorari
Certiorari
Certiorari is a type of writ seeking judicial review, recognized in U.S., Roman, English, Philippine, and other law. Certiorari is the present passive infinitive of the Latin certiorare...
.
Additionally, the Choctaw Nation
Choctaw Nation of Oklahoma
The Choctaw Nation of Oklahoma is a semi-autonomous Native American homeland comprising twelve tribal districts. The Choctaw Nation maintains a special relationship with both the United States and Oklahoma governments...
used the same pull-tab system and also filed suit in Federal District Court, 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
Affirmed. Justice Stephen BreyerStephen Breyer
Stephen Gerald Breyer is an Associate Justice of the U.S. Supreme Court. Appointed by President Bill Clinton in 1994, and known for his pragmatic approach to constitutional law, Breyer is generally associated with the more liberal side of the Court....
delivered the opinion of the court. 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. Breyer 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'ConnorSandra Day O'Connor
Sandra Day O'Connor is an American jurist who was the first female member of the Supreme Court of the United States. She served as an Associate Justice from 1981 until her retirement from the Court in 2006. O'Connor was appointed by President Ronald Reagan in 1981...
dissented, joined by Justice David Souter
David Souter
David Hackett Souter is a former Associate Justice of the Supreme Court of the United States. He served from 1990 until his retirement on June 29, 2009. Appointed by President George H. W. Bush to fill the seat vacated by William J...
. 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." The court did not do so in this case, and she respectfully dissented.