Central Mach. Co. v. Arizona State Tax Comm’n, 448 U.S. 160 (1980)

Central Machinery Co. v. Arizona State Tax Commission

No. 78-1604

Argued January 14, 1980
Decided June 27, 1980
448 U.S. 180

APPEAL FROM THE SUPREME COURT OF ARIZONA

Syllabus

Held: Arizona had no jurisdiction to impose a tax on appellant Arizona corporation’s sale of farm machinery to an Indian tribe, where the sale took place on an Indian reservation even though appellant did not have a permanent place of business on the reservation and was not licensed to trade with Indians. Since the transaction was plainly subject to regulation under the federal statutes and implementing regulations governing the licensing of Indian traders, federal law preempts the asserted state tax. It is irrelevant that appellant was not a licensed Indian trader, since it is the existence of the Indian trader statutes, not their administration, that preempts the field of transactions with Indians occurring on reservations. Nor is it relevant that appellant did not maintain a permanent place of business on the reservation, since the Indian trader statutes and regulations apply no less to a nonresident who sells goods to Indians on a reservation than they do to a resident trader. The purpose of these statutes and regulations to protect Indians from becoming victims of fraud in dealings with sellers of goods would be easily circumvented if a seller could avoid federal regulations simply by failing to adopt a permanent place of business on a reservation or to obtain a federal license. Pp. 163-166.

121 Ariz. 183, 589 P.2d 426, reversed.

MARSHALL, J., delivered the opinion of the Court, in which BURGER, C.J., and BRENNAN, WHITE, and BLACKMUN, JJ., joined. STEWART, J., filed a dissenting opinion, in which POWELL, REHNQUIST, and STEVENS, JJ., joined, post, p. 166. POWELL, J., filed a dissenting opinion, post, p. 170.