Sturgeon v. Frost

The National Park Service regulations regarding ‘non-public’ lands within Alaska are inconsistent with the Alaska National Interest Lands Conservation Act (ANILCA).

Petitioner was operating his hover craft on the Nation River in Alaska. National Park Rangers informed petitioner that National Park Service regulations prohibit hover craft use in federally managed preservation areas. Petitioner in the US District Court for the District of Alaska, seeking declaratory and injunctive relief. Petitioner claimed that the Alaska National Interest Lands Conservation Act (ANILCA) limits the Park Service regulations on state owned waters. The Nation River is owned by the state and state law permits hover craft use. The District Court granted summary judgment to the respondent. The Ninth Circuit affirmed and held that the Park Service can enforce its regulations on both ‘public’ and ‘non-public’ lands because the regulations do not apply ‘solely to public lands.’ The Ninth Circuit reasoned that the ANILCA only bars regulations that apply ‘solely to public lands.’

The Supreme Court vacated and remanded the ruling, holding that the lower court did not interpret the relevant section of ANILCA with the proper context.