Sturgeon v. Frost

Sturgeon v. Frost

Argued January 20, 2016
Decided March 22, 2016
Full case name Sturgeon v. Frost, Alaska Regional Director of the National Park Service, et al.
Docket nos. 14–1209
Citations

577 U.S. ___ (more)

Opinion announcement Opinion announcement
Prior history On writ of certiorari to the United States Court of Appeals for the Ninth Circuit
Court membership
Chief Justice
John G. Roberts
Case opinions
Majority Roberts, joined by a unanimous Court
Laws applied
Alaska National Interest Lands Conservation Act, 16 U.S.C. § 3103(c).

Sturgeon v. Frost, 577 U.S. ___ (2016), was a case in which the Supreme Court of the United States held that under section 103(c) of the Alaska National Interest Lands Conservation Act,[1] the National Park Service may only regulate "non-public" lands in Alaska according to Alaska-specific laws.[2]

Background

The case arose when an Alaskan hunter was informed by the National Park Service that he could not pilot his hovercraft on the Nation River in the Yukon–Charley Rivers National Preserve.[3] The hunter filed a lawsuit in which he argued that section 103(c) of the Alaska National Interest Lands Conservation Act limited the National Park Service's jurisdiction over portions of the river that were owned by the State of Alaska.[4] The United States District Court for the District of Alaska ruled in favor of the Park Service, and the United States Court of Appeals for the Ninth Circuit affirmed.[5] The Ninth Circuit held that National Park Service regulations "apply to federally managed preservation areas across the country" and that "the Park Service may enforce nationally applicable regulations on both 'public' and 'non-public' property within the boundaries of conservation system units in Alaska".[6]

Opinion of Court

In a unanimous opinion written by Chief Justice John Roberts, the Supreme Court reversed the Ninth Circuit's ruling.[7] Justice Roberts characterized the Ninth Circuit's ruling as "a topsy-turvy approach" because the Ninth Circuit's interpretation of the Alaska National Interest Lands Conservation Act was "ultimately inconsistent with both the text and context of the statute as a whole."[8] Rejecting the Ninth Circuit's conclusions, Justice Roberts held that the Act directs the Park Service to regulate "non-public" lands in Alaska according to "Alaska-specific provisions".[9] Additionally, Justice Roberts wrote that "Section 103(c) draws a distinction between 'public' and 'non-public' lands within the boundaries of conservation system units in Alaska."[10] However, the Supreme Court did not rule on whether the Nation River constituted a "public land" for the purposes of the Act or whether the authority of the Park Service's regulations extend to "non-public" lands.[11] To conduct further fact finding with respect to these issues, the Supreme Court vacated the Ninth Circuit's ruling and remanded the case for further proceedings.[12]

Commentary and analysis

In his analysis of the case for SCOTUSblog, Todd Henderson suggested that the Court avoided several key questions because "the stakes in this case are potentially huge" and the Court wanted to "leave for another day the tough questions about federal power over lands in Alaska and perhaps elsewhere throughout the West."[13]

See also

References

  1. ↑ Codified at 16 U.S.C. § 3103(c).
  2. ↑ Sturgeon v. Frost, No. 14–1209, 577 U.S. ___, slip op. at 12–15 (2016).
  3. ↑ Sturgeon, slip op. at 1–6.
  4. ↑ Sturgeon, slip op. at 1–2, 6–7.
  5. ↑ Sturgeon, slip op. at 2.
  6. ↑ Sturgeon, slip op. at 11–12.
  7. ↑ Sturgeon, slip op. at 12–16.
  8. ↑ Sturgeon, slip op. at 12–14.
  9. ↑ Sturgeon, slip op. at 14.
  10. ↑ Sturgeon, slip op. at 14–15.
  11. ↑ Sturgeon, slip op. at 15–16.
  12. ↑ Sturgeon, slip op. at 16.
  13. ↑ Todd Henderson, Opinion analysis: A rebuke of the Ninth Circuit, and nothing more, SCOTUSblog (Mar. 23, 2016).

External links

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