March 22, 2016

Supreme Court Decides Sturgeon v. Frost

On March 22, 2016, the Supreme Court of the United States decided Sturgeon v. Frost, No. 14-1209, vacating a decision of the Ninth Circuit and leaving open the possibility that Section 103(c) of the Alaska National Interest Lands Conservation Act (ANILCA) could prevent the National Park Service from regulating use of a “hovercraft” through a federally managed preservation area in Alaska.

John Sturgeon hunted moose along the Nation River in Alaska. To get to the hunting grounds over otherwise shallow and difficult-to-navigate areas, Sturgeon traveled by hovercraft, an amphibious vehicle capable of gliding over land and water. The land over which Sturgeon traveled included a stretch of the Nation River that flowed through the Yukon-Charley Rivers National Preserve (the “Yukon-Charley”), which is managed by the National Park Service. National Park Service regulations bar use of hovercraft in federal preservation areas.

In 2007, three Park Service Rangers ordered Sturgeon to remove his hovercraft from the preserve. Fearing criminal prosecution, Sturgeon sued the Park Service and several officials in the United States District Court for the District of Alaska, seeking declaratory and injunctive relief that would permit him to operate the hovercraft within the Yukon-Charley. The district court granted summary judgment to the Park Service and denied injunctive and declaratory relief. The Ninth Circuit affirmed, reasoning that Park Service regulations allowed the Park Service to enforce nationally applicable regulations on both public and non-public property within the boundaries of Alaska and finding nothing in ANILCA stating otherwise.

The Supreme Court vacated the Ninth Circuit’s decision, holding the circuit court’s interpretation was inconsistent with both the text and context of ANCILA. “ANILCA repeatedly recognizes that Alaska is different,” the Court explained, and carves out numerous Alaska-specific exceptions to the Park Service’s general authority over federally managed preservation areas. The Ninth Circuit’s decision did not reflect the “simple truth that Alaska is often the exception, not the rule” and would “prevent the Park Service from recognizing Alaska’s unique conditions.” Thus, the Court held, ANILCA “contemplates the possibility that all the land within [specific areas] in Alaska may be treated different from federally managed preservation areas across the country.”

The Supreme Court vacated and remanded the case to the Ninth Circuit, expressly leaving open other interpretive issues under Section 103(c) of ANILCA — questions that “touch on vital issues of state sovereignty, on the one hand, and federal authority, on the other.”

Chief Justice Roberts delivered the opinion for a unanimous Court.

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