Bryan v. Itasca County
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426 U.S. 373 (1976)
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U.S. Supreme Court
Bryan v. Itasca County, 426 U.S. 373 (1976)
Bryan v. Itasca County
Argued April 20, 1976
Decided June 14, 1976
426 U.S. 373
Petitioner, an enrolled Chippewa Indian, brought this suit in state court seeking a declaratory judgment that the State of Minnesota and respondent county lacked authority to impose a personal property tax on his mobile home located on land held in trust for members of his tribe, and that imposition of such a tax contravened federal law. The trial court rejected the contention. The Minnesota Supreme Court affirmed, holding that the grant of civil jurisdiction to the State in § 4(a) of Pub.L. 280 includes taxing authority, and, since § 4(b) does not exempt nontrust property from such authority, the county had power to assess the tax. Section 4(a) gave various States, including Minnesota, with respect to all Indian country within the State except as specifically exempted,
"jurisdiction over civil causes of action between Indians or to which Indians are parties which arise in the areas of Indian country listed . . . to the same extent that such State . . . has jurisdiction over other civil causes of action, and those civil laws of such State . . . that are of general application to private persons or private property shall have the same force and effect within such Indian country as they have elsewhere within the State. . . ."
Though tax laws are not specifically mentioned, the State Supreme Court concluded that they were included, since the exempting provision, § 4(b), does not exempt nontrust property, but states that
"[n]othing in this section shall authorize the . . . taxation of any real or personal property . . . belonging to any Indian or any Indian tribe . . . that is held in trust by the United States. . . ."
Held: Public Law 280 did not grant States the authority to impose taxes on reservation Indians. Pp. 426 U. S. 379-393.
(a) The central focus of Pub.L. 280, embodied in § 2 of the Act, was to confer on the States criminal jurisdiction with respect to crimes involving Indians, and no mention was made of a congressional intent to authorize the States to tax Indians or Indian property on Indian reservations, a significant omission in light of applying the canons of construction to statutes affecting Indian immunities, where some mention would normally be expected had Congress contemplated sweeping change in the status of reservation Indians. Pp. 426 U. S. 379-383.
(b) Section 4(a) seems to have been intended primarily to provide a state forum for resolving private legal disputes involving Indians. Pp. 426 U. S. 383-386.
(c) When Title IV of the Civil Rights Act of 1968 amended Pub.L. 280 to require tribal consent to any new state jurisdiction, Congress in effect characterized the relevant part of Pub.L. 280 as conferring the power to resolve private civil controversies, and the legislative history of Title IV would make it difficult to construe § 4 jurisdiction acquired pursuant to that Title as extending general state regulatory power, including taxing power, to govern Indian reservations. Pp. 426 U. S. 386-387.
(d) Public L. 280 was plainly not meant to effect total assimilation, and nothing in its legislative history suggests otherwise. The same Congress that enacted Pub.L. 280 also enacted several termination Acts, indicating that Congress well knew how directly to express its intent to confer upon the States general civil regulatory powers, including taxation. Pp. 426 U. S. 387-390.
(e) Section 4(b), which is "entirely consistent with, and in effect . . . a reaffirmation of, the law as it stood prior to its enactment," Kirkwood v. Arenas, 243 F.2d 863, 866 (CA9), should, as an admittedly ambiguous statute, be construed in favor of the Indians and against abolishing their tax immunities by implication. Pp. 426 U. S. 390-393.
303 Minn. 395, 228 N.W.2d 249, reversed.
BRENNAN, J., delivered the opinion for a unanimous Court.