## Facts

- Russell Bryan, an enrolled member of the Minnesota Chippewa Tribe, lived in a mobile home situated on reservation trust land in Minnesota.
- Itasca County assessed a personal property tax on Bryan’s mobile home.
- Bryan sought a declaratory judgment that Minnesota and the county lacked authority to impose the tax under federal law governing Indian country and reservation tax immunity.
- Minnesota relied on Public Law 280, including 28 U.S.C. § 1360(a), arguing that the grant of state “civil laws ... of general application” in Indian country included taxing authority.
- The Minnesota Supreme Court upheld the tax, reasoning that because 28 U.S.C. § 1360(b) expressly protected trust property from taxation, non-trust Indian property could be taxed under § 1360(a).

## Issues

1. Whether Public Law 280 authorizes Minnesota to impose a personal property tax on a mobile home owned by a reservation Indian and located on trust land in Indian country.
2. Whether Public Law 280’s grant of “civil jurisdiction” extends beyond adjudication of private civil disputes to confer general civil regulatory authority, including taxation, over Indians and Indian property on reservations.

## Decision

- The Supreme Court reversed.
- Public Law 280 does not grant states authority to tax reservation Indians or their property in Indian country.
- The county’s personal property tax assessment against Bryan’s mobile home was unauthorized under Public Law 280.

## Legal Principles

- Public Law 280’s civil-jurisdiction provisions primarily provide a state forum to adjudicate private civil disputes involving Indians; they do not confer general state civil regulatory power in Indian country.
- State taxing authority over Indians and Indian property on reservations is not presumed and requires clear congressional authorization.
- Statutes affecting Indians are construed liberally in favor of Indians, and ambiguities are resolved against finding diminished tribal immunity or authority.
- 28 U.S.C. § 1360(b)’s express protection of trust property from taxation does not imply affirmative state authority to tax non-trust Indian property; it is consistent with preexisting limits on state taxation in Indian country.
- Later congressional descriptions of Public Law 280 (including in 1968 amendments requiring tribal consent for new jurisdictional extensions) support reading the statute as authorizing adjudication of private controversies rather than broad state regulation.

## Conclusion

The Court held that Public Law 280 does not authorize state and local taxation of reservation Indians or their property in Indian country, limiting the statute’s “civil jurisdiction” grant to adjudicatory authority over private civil causes of action rather than general civil regulatory power.


Bryan v. Itasca County, 426 U.S. 373 (1976)