Maryboy v. Utah State Tax Commission

In Maryboy v. Utah State Tax Commission, 904 P.2d 662, 664 (Utah 1995) members of the Navajo Native American Tribe protested income tax assessments. They appealed the Utah State Tax Commission's decision that required them to pay $ 10,855.38 in taxes, penalties, and interest before they were allowed to appeal. Id. The protesters asserted that the Commission's order that they deposit the alleged tax deficiency "violated their constitutional right to have open access to the courts of this state." Id. at 670. The Court held that in the Maryboys' case, the statute requiring that the deficiency be deposited did not preclude reasonable access to judicial review because the Maryboys were able to pay the alleged deficiency.