Oklahoma Tax Commission v. United States
Encyclopedia
Oklahoma Tax Commission v. United States, 319 U.S. 598
(1943), was a case in which the Supreme Court of the United States
held that Indian land that Congress has exempted from direct taxation by a state is also exempt from state estate taxes.
passed , amended by (1926), which provided that lands allotted to members of the Five Civilized Tribes
were restricted to members of that tribe unless the restrictions were lifted by the United States Secretary of the Interior
. Three enrolled full-blood members of the tribes died in 1930, 1932, and 1938, leaving their estates to their heirs, all of whom were Indians. The estates included restricted lands and similarly restricted securities and funds held in trust by the Secretary of Interior.
The Oklahoma Tax Commission
imposed an estate tax on the three estates, the Secretary of the Interior paid the taxes under protest and then filed an action in the United States District Court for the Eastern District of Oklahoma
to recover the taxes. The District Court entered a judgment for Oklahoma and the United States appealed.
On appeal, the Tenth Circuit Court
reversed. The United States contended that the right to transfer land in these cases flowed not from state law, but from federal law, and therefore the state did not have the power to impose taxes without the consent of the United States. The appellate court cited Childers v. Beaver, , a case that was fundamentally the same as the instant case, in support of their decision. Oklahoma appealed and the Supreme Court granted certiorari
to hear the case.
delivered the opinion of the court. Black stated that the estates of the Indians could be divided into four categories, a) restricted land exempt from direct taxation; b) land not exempt from direct taxation; c) restricted cash and securities held in trust by the Secretary of the Interior; and d) other property. Black held that the restricted land in the first category was exempt from state taxation, but the remainder of the estates were not exempt. The case was then remanded to the District Court.
dissented, stating that the court was rejecting over a century of jurisprudence in their opinion. Murphy stated that while tax exemptions are typically viewed with skepticism by the court system, this was not an ordinary case involving ordinary citizens. Instead, it involved a people that are wards of the United States, "and towards whom Congress has fashioned a policy of protection due to obligations well known to all of us." Murphy believed that for a state to tax Indians, there must be an affirmative, unequivocal grant by Congress to the states. Since there was no such grant, he would have held that the estates were exempt from state taxation.
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...
(1943), 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 land that Congress has exempted from direct taxation by a state is also exempt from state estate taxes.
Background
In 1908 CongressUnited States Congress
The United States Congress is the bicameral legislature of the federal government of the United States, consisting of the Senate and the House of Representatives. The Congress meets in the United States Capitol in Washington, D.C....
passed , amended by (1926), which provided that lands allotted to members of the Five Civilized Tribes
Five Civilized Tribes
The Five Civilized Tribes were the five Native American nations—the Cherokee, Chickasaw, Choctaw, Creek, and Seminole—that were considered civilized by Anglo-European settlers during the colonial and early federal period because they adopted many of the colonists' customs and had generally good...
were restricted to members of that tribe unless the restrictions were lifted by the United States Secretary of the Interior
United States Secretary of the Interior
The United States Secretary of the Interior is the head of the United States Department of the Interior.The US Department of the Interior should not be confused with the concept of Ministries of the Interior as used in other countries...
. Three enrolled full-blood members of the tribes died in 1930, 1932, and 1938, leaving their estates to their heirs, all of whom were Indians. The estates included restricted lands and similarly restricted securities and funds held in trust by the Secretary of Interior.
The Oklahoma Tax Commission
Oklahoma Tax Commission
The Oklahoma Tax Commission is the Oklahoma state government agency that collects taxes and enforces the internal revenue laws of the state. The Commission is composed of three members appointed by the Governor of Oklahoma with the approval of the Oklahoma Senate...
imposed an estate tax on the three estates, the Secretary of the Interior paid the taxes under protest and then filed an action in the United States District Court for the 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,...
to recover the taxes. The District Court entered a judgment for Oklahoma and the United States appealed.
On appeal, the Tenth Circuit Court
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...
reversed. The United States contended that the right to transfer land in these cases flowed not from state law, but from federal law, and therefore the state did not have the power to impose taxes without the consent of the United States. The appellate court cited Childers v. Beaver, , a case that was fundamentally the same as the instant case, in support of their decision. Oklahoma appealed and 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...
to hear the case.
Opinion of the Court
Justice Hugo BlackHugo Black
Hugo Lafayette Black was an American politician and jurist. A member of the Democratic Party, Black represented Alabama in the United States Senate from 1927 to 1937, and served as an Associate Justice of the Supreme Court of the United States from 1937 to 1971. Black was nominated to the Supreme...
delivered the opinion of the court. Black stated that the estates of the Indians could be divided into four categories, a) restricted land exempt from direct taxation; b) land not exempt from direct taxation; c) restricted cash and securities held in trust by the Secretary of the Interior; and d) other property. Black held that the restricted land in the first category was exempt from state taxation, but the remainder of the estates were not exempt. The case was then remanded to the District Court.
Dissent
Justice Frank MurphyFrank Murphy
William Francis Murphy was a politician and jurist from Michigan. He served as First Assistant U.S. District Attorney, Eastern Michigan District , Recorder's Court Judge, Detroit . Mayor of Detroit , the last Governor-General of the Philippines , U.S...
dissented, stating that the court was rejecting over a century of jurisprudence in their opinion. Murphy stated that while tax exemptions are typically viewed with skepticism by the court system, this was not an ordinary case involving ordinary citizens. Instead, it involved a people that are wards of the United States, "and towards whom Congress has fashioned a policy of protection due to obligations well known to all of us." Murphy believed that for a state to tax Indians, there must be an affirmative, unequivocal grant by Congress to the states. Since there was no such grant, he would have held that the estates were exempt from state taxation.