 Almost immediately after the decision , the BIA , on directions from Assistant Secretary of the Interior Kenneth Smith , proposed federal regulations that would have severely limited the ability of the tribes to impose severance taxes . Following numerous complaints from the tribes , the BIA abandoned that plan . The Jicarilla tribe has also purchased the Palmer Oil Company , becoming the first Indian tribe to have 100 % ownership of an oil production firm . The case is a landmark case in Native American case law , having been cited in approximately 400 law review articles as of July 2010 . Almost all tribes that have mineral deposits now impose a severance tax , based on the Merrion decision and has been used as the basis for subsequent decisions supporting tribal taxing authority . Numerous books also mention the case , whether in regards to tribal sovereignty or taxation . 
