Atkinson Trading Co. v. Shirley

Atkinson Trading Company (Atkinson) (plaintiff), a non-Indian business, owned and operated a hotel on non-Indian fee land located within the Navajo Reservation. The Navajo Nation imposed an occupancy tax on all reservation hotel rooms, collected by hotel owners and remitted to the Navajo Tax Commission (NTC) (defendant). Atkinson challenged the tribe's authority to tax it, but the NTC, the Navajo courts, and lower federal courts all upheld the tax, with the Tenth Circuit relying on a contractual relationship theory under Montana v. United States. The Supreme Court granted certiorari.