Confederated Tribes & Bands of the Yakama Indian Nation v. Alcohol & Tobacco Tax & Trade Bureau

Confederated Tribes and Bands of the Yakama Indian Nation (“the Yakama Nation” or “the tribe”) appeals the district court’s summary judgment in the Yakama Nation’s action seeking to bar defendant federal agencies and officials from imposing the federal excise tax on tobacco products manufactured by King Mountain Tobacco Co. (“King Mountain”). The Yakama Nation alleges that King Mountain is entitled to exemptions from the excise tax under the General Allotment Act, 25 U.S.C. § 331 et seq., and the Treaty with the Yakama, 12 Stat. 951 (1855). Defendants, in turn, contend that the Anti-Injunction Act and the tax exception to the Declaratory Judgment Act bar the Yaka-ma Nation’s claims seeking injunctive and declaratory relief.

We hold that the Anti-Injunction Act deprived the district court of jurisdiction to hear the Yakama Nation’s claims. We therefore vacate the judgment and remand with instructions to dismiss.

FACTUAL AND PROCEDURAL BACKGROUND

The Yakama Nation, King Mountain, and Delbert Wheeler, Sr., brought suit for injunctive and declaratory relief barring the imposition of the federal tobacco excise tax on King Mountain. The tobacco excise tax applies to…