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Sturgeon v. Frost

ELR Citation: 46 ELR 20057
Nos. 14-1209, (U.S., 03/22/2016)

The U.S. Supreme Court reversed a lower court decision barring a hunter from using a hovercraft over a stretch of the Nation River that flows through the Yukon-Charley Rivers National Preserve, a conservation system unit in Alaska that is managed by NPS. The hunter argued that NPS' ban on hovercraft vehicles did not apply because the river was owned by the state of Alaska, but a district court and the Ninth Circuit granted summary judgment in favor of NPS. According to the Ninth Circuit, the hovercraft regulation “applies to all federal-owned lands and waters administered by [NPS] nationwide, as well as all navigable waters lying within national parks.” But the Supreme Court reversed. The Alaska National Interest Lands Conservation Act (ANILCA) carves out numerous Alaska-specific exceptions to NPS' general authority over federally managed preservation areas. Relevant to this case, ANILCA §103(c) draws a distinction between “public” and “non-public” lands within the boundaries of conservation system units in Alaska. According to the Ninth Circuit's reading of the statute, if NPS wanted to differentiate between “public” and “non-public” land in an Alaska-specific way, it would have to regulate the “non-public” land pursuant to rules applicable outside Alaska, and the “public” land pursuant to Alaska-specific provisions. The Court concluded that this is an implausible reading of the statute. But the Court did not reach the remainder of the parties’ arguments, including whether the Nation River qualifies as “public land” for purposes of ANILCA, whether NPS has authority to regulate the hunter's activities on the Nation River, or whether NPS has authority under ANILCA over “public” and “non-public” lands within the boundaries of conservation system units in Alaska. Roberts, C.J., delivered the opinion for a unanimous Court.