Oklahoma Tax Commission v. Citizen Band, Potawatomi Indian Tribe of Oklahoma facts for kids
Quick facts for kids Okla. Tax Commission v. Citizen Band, Potawatomi Indian Tribe of Okla. |
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| Argued January 7, 1991 Decided February 26, 1991 |
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| Full case name | Oklahoma Tax Commission v. Citizen Band, Potawatomi Indian Tribe of Oklahoma |
| Citations | 498 U.S. 505 (more)
111 S. Ct. 905; 112 L. Ed. 2d 1112; 1991 U.S. LEXIS 1298
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| Prior history | 888 F.2d 1303 (10th Cir. 1989); cert. granted, 498 U.S. 806 (1990). |
| Subsequent history | Remanded, 932 F.2d 1355 (10th Cir. 1991); judgment affirmed, 969 F.2d 943 (10th Cir. 1992). |
| Holding | |
| The tribe was not subject to state sales taxes on sales made to tribal members, but that they were liable for taxes on sales to non-tribal members. | |
| Court membership | |
| Case opinions | |
| Majority | Rehnquist, joined by unanimous |
| Concurrence | Stevens |
| Laws applied | |
| Tribal sovereign immunity | |
This article is about an important case from 1991. It was called Oklahoma Tax Commission v. Citizen Band, Potawatomi Indian Tribe of Oklahoma. The Supreme Court of the United States made a big decision. They said that the Potawatomi Tribe did not have to pay state sales taxes. This was for things they sold to their own tribal members. But, they did have to collect taxes for things sold to people who were not tribal members. This case helped explain rules about taxes and Native American tribes.
Contents
Understanding the Background
The Potawatomi people originally lived near the Wabash River in Indiana. They were known as the Mission Band of Potawatomi. After 1833, they were moved to Kansas. There, they lost much of their land because of a system called "allotment."
In 1867, the tribe made a treaty with Kansas. They sold their land in Kansas. This allowed them to buy new land in what was then called the Indian Territory. Today, this area is Oklahoma. At this time, they also became citizens of the United States. From then on, they have been known as the Citizen Potawatomi Nation.
The Tax Dispute Begins
For many years, the Potawatomi Tribe sold cigarettes on their tribal lands. They did not collect Oklahoma's cigarette tax. In 1987, the Oklahoma Tax Commission asked the tribe to pay $2.7 million. This amount was for taxes from 1982 to 1986.
The tribe then decided to sue the state. They filed their case in the U.S. District Court.
District Court's Decision
The District Court is the first level of federal courts. The tribe asked the court to make a quick decision in their favor. This is called a summary judgment. The court said no to this request.
After a trial, the District Court made its decision. It ruled that sales to tribal members were free from state taxes. However, sales to people who were not tribal members could be taxed.
Appealing the Decision
The Potawatomi Tribe did not agree with the full decision. They said they had "tribal sovereign immunity." This means they believed they were free from all state taxes on their lands.
The State of Oklahoma argued that the tribe had given up its immunity. They said this happened when the tribe filed the case in court.
Circuit Court's Ruling
The tribe appealed their case to the Tenth Circuit Court of Appeals. This court is a higher federal court. The Tenth Circuit Court decided that Oklahoma could not collect any state sales taxes on tribal lands. This included sales to both tribal members and non-tribal members.
Oklahoma then appealed this decision. The Supreme Court of the United States agreed to hear the case. This is called granting certiorari.
The Supreme Court's Opinion
The Supreme Court's decision partly agreed and partly disagreed with the lower courts. Chief Justice Rehnquist wrote the opinion for the Court. All the judges agreed with his main points.
Chief Justice Rehnquist first said that a tribe does not give up its immunity just by suing in court. He noted that courts had already decided tribes were protected from lawsuits against them. This protection exists unless Congress says otherwise.
Next, the state argued that land held "in trust" for a tribe was different from reservation land. Chief Justice Rehnquist did not agree. He said that tribal land, whether held in trust or as part of a reservation, is set aside for the tribe's use. Because of this, it qualifies for immunity from state taxes.
However, the Court also said the Tenth Circuit Court was wrong. The tribe did have to collect sales taxes on cigarettes sold to people who were not tribal members.
Justice Stevens' Concurring Opinion
Justice Stevens wrote a separate opinion. This is called a concurring opinion. In his opinion, he mostly talked about how the idea of immunity applied to the facts of this specific case.
