Atkinson Trading Co. v. Shirley

Atkinson Trading Co. v. Shirley, 532 U.S. 645 (2001), was a United States Supreme Court case in which the Court held the Navajo Nation's imposition of a hotel occupancy tax upon nonmembers on non-Indian fee land within its reservation is invalid.

The Atkinson Trading Company, Inc. owns a hotel, restaurant, cafeteria, gallery, curio shop, retail store, and recreational vehicle facility, which are located on non-Indian fee land within the Navajo Nation Reservation.

The tribe provided police, fire, and ambulance services for the area, including the hotel complex.

Atkinson sought a declaratory judgment that the tax was invalid under Montana v. United States.

Rehnquist stated that while Indian tribes have unique attributes of sovereignty over both their members and their territory, they do not have civil authority past those limits, with minor exceptions.