Cite as: 532 U. S. 645 (2001)
Opinion of the Court
Attorney General Cruden, Deputy Solicitor General Kneed-ler, Edward C. DuMont, E. Ann Peterson, and William B. Lazarus.*
Chief Justice Rehnquist delivered the opinion of the Court.
In Montana v. United States, 450 U. S. 544 (1981), we held that, with limited exceptions, Indian tribes lack civil authority over the conduct of nonmembers on non-Indian fee land within a reservation. The question with which we are presented is whether this general rule applies to tribal attempts to tax nonmember activity occurring on non-Indian fee land. We hold that it does and that neither of Montana's exceptions obtains here.
In 1916, Hubert Richardson, lured by the possibility of trading with wealthy Gray Mountain Navajo cattlemen, built the Cameron Trading Post just south of the Little Colorado River near Cameron, Arizona. G. Richardson, Navajo Trader 136-137 (1986). Richardson purchased the land
*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 John Patrick Guhin, Deputy Attorney General, and by the Attorneys General for their respective States as follows: Bill Pryor of Alabama, Ken Salazar of Colorado, Robert A. Butterworth of Florida, Jennifer M. Gran-holm of Michigan, Mike Moore of Mississippi, Wayne Stenehjem of North Dakota, W. A. Drew Edmondson of Oklahoma, and Jan Graham of Utah; for the Association of American Railroads by Lynn H. Slade, Walter E. Stern, and William C. Scott; for the Interstate Natural Gas Association of America by Michael E. Webster and Neil G. Westesen; for Proper Economic Resource Management, Inc., by Randy V. Thompson; and for Roberta Bugenig et al. by James S. Burling.
Briefs of amici curiae urging affirmance were filed for the Assiniboine and Sioux Tribes of the Fort Peck Indian Reservation et al. by William R. Perry and Arthur Lazarus, Jr.; for the Colorado River Indian Tribes et al. by Susan M. Williams; for the Confederated Tribes of the Umatilla Indian Reservation et al. by Michael L. Roy and Jeffrey D. Lerner; and for the Shakopee Mdewakanton Sioux (Dakota) Community et al. by Andrew M. Small and Steven F. Olson.
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