452
Opinion of the Court
Charles Rothfeld argued the cause for petitioner. With him on the briefs were Gary A. Winters, Stanley Johnston, and David Allen Miley.
Dennis W. Arrow argued the cause for respondent. With him on the briefs was Bob Rabon.
Paul A. Engelmayer argued the cause for the United States as amicus curiae urging affirmance. With him on the brief were Solicitor General Days, Assistant Attorney General Schiffer, and Deputy Solicitor General Kneedler.*
Justice Ginsburg delivered the opinion of the Court.
This case concerns the taxing authority of the State of Oklahoma over the Chickasaw Nation (Tribe) and its members.1 We take up two questions: (1) May Oklahoma impose
*Briefs of amici curiae urging reversal were filed for the State of South Dakota et al. by Mark W. Barnett, Attorney General of South Dakota, and Lawrence E. Long, Chief Deputy Attorney General, and by the Attorneys General for their respective States as follows: Daniel E. Lungren of California, Richard P. Ieyoub of Louisiana, Mike Moore of Mississippi, Joseph P. Mazurek of Montana, Frankie Sue Del Papa of Nevada, Heidi Heitkamp of North Dakota, Theodore R. Kulongoski of Oregon, Jan Graham of Utah, James E. Doyle of Wisconsin, and Joseph B. Meyer of Wyoming; and for the Petroleum Marketers Association of America et al. by Robert S. Bassman and Alphonse M. Alfano. Briefs of amici curiae urging affirmance were filed for the Cherokee
Nation by David A. Mullon, Jr., and L. Susan Work; for the Cheyenne-Arapaho Tribes of Oklahoma et al. by Kim Jerome Gottschalk, Rodney B. Lewis, Bertram Hirsch, Doug Nash, Carol Barbero, Patrice Kunesh, and Christopher D. Quale; for the Choctaw Nation by Glenn M. Feldman; for the Navajo Nation Oil and Gas Co., Inc., by Paul E. Frye and Wayne H. Bladh; and for the Sac and Fox Nation by G. William Rice and Gregory H. Bigler.
1 For the Court's most recent encounters with questions of state authority to tax Indian Tribes and their members, and tribal immunity from state taxation, see Department of Taxation and Finance of N. Y. v. Mil-helm Attea & Bros., 512 U. S. 61 (1994); Oklahoma Tax Comm'n v. Sac and Fox Nation, 508 U. S. 114 (1993); County of Yakima v. Confederated Tribes and Bands of Yakima Nation, 502 U. S. 251 (1992); Oklahoma Tax
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