Fort Leavenworth R.R. Co. v. Lowe
United States Supreme Court
114 U.S. 525 (1885)
The U.S. acquired the Fort Leavenworth reservation from France in 1803, retaining only ordinary proprietor rights (not exclusive jurisdiction) once Kansas joined the Union in 1861 without a jurisdiction-reservation clause. Kansas later ceded exclusive jurisdiction over the reservation to the U.S. by statute, but included a savings clause preserving its right to tax railroads and corporations located on the reservation; Kansas then taxed the Fort Leavenworth Railroad Company, which paid under protest and sued, arguing the savings clause conflicted with the federal government's exclusive jurisdiction under the cession.
Whether, if the federal government obtains jurisdiction over state land by a state's act of cession rather than by purchase, the state may retain the power to tax entities located on the land.