Quinault Indian Nation v. Grays Harbor County

This case presents the question whether Congress’s intention to permit state taxation of Indian land unambiguously encompasses the unique taxation scheme now before us. See Montana v. Blackfeet Tribe of Indians, 471 U.S. 759, 765 , 105 S.Ct. 2399 , 85 L.Ed.2d 753 (1985) (states are permitted to tax Indians “only when Congress has made its intention to [permit such taxation] unmistakably clear”).

In 1998, the Quinault Indian Nation (“Quinault Nation” or “Nation”) purchased approximately 4,500 acres of forest land, most of which was located in Grays Harbor County, Washington (“Grays Harbor” or “the County”). Two years later, the Qui-nault Nation transferred the land to the United States to hold in trust for the Nation, thereby triggering a $58,000 compensating tax imposed by the County. Under Washington’s tax law, land classi fied for forest use is assigned a reduced property valuation for property tax purposes. Under certain circumstances, the sale or transfer of forest use land deprives the property of its favorable tax status and triggers the imposition of a tax on the seller-transferor.

Believing that the County lacked federal congressional authority to levy this tax, the…