Ahtna, Inc. v. State of Alaska, Department of Transportation & Public Facilities, State of Alaska, Department of Transportation & Public Facilities v. AHTNA, Inc., State of Alaska, Department of Transportation & Public Facilities v. Ahtna, Inc., 520 P.3d 131

Klutina Lake Road (Brenwick-Craig Road) runs ~25 miles across land largely owned by Ahtna, Inc.; the State cleared a 100-foot-wide swath and asserted an RS 2477 right-of-way (50 feet each side of centerline).
Ahtna sued seeking a declaration the land was free of any RS 2477 right-of-way (and injunctive relief), arguing either that preexisting aboriginal title made the land non-public (so no RS 2477 conveyance could occur) or, alternatively, that any RS 2477 right-of-way is limited to ingress and egress.
The parties stipulated that a 100-foot RS 2477 right-of-way exists but preserved appeal rights on legal issues decided on summary judgment.
The superior court denied Ahtna’s summary judgment on aboriginal-title grounds (holding ANCSA precluded that defense) and granted Ahtna’s motion declaring RS 2477 rights-of-way are limited to ingress and egress.
The Supreme Court affirmed the superior court’s ruling that ANCSA retroactively validates pre-ANCSA conveyances (so aboriginal-title defenses fail), but vacated the ruling that RS 2477 is limited to mere ingress/egress and remanded for factual inquiry about specific proposed uses.

Issue	Plaintiff's Argument (Ahtna)	Defendant's Argument (State)	Held
Whether ANCSA extinguishes aboriginal-title defenses to pre-ANCSA RS 2477 conveyances	Aboriginal title existed when RS 2477 grants were made, so the land was not "public" and no valid RS 2477 conveyance could occur; ANCSA cannot validate a conveyance that never existed; §4(c) forbids only claims, not defenses	ANCSA §4(a) treats prior conveyances as extinguishing aboriginal title and therefore retroactively validates pre-ANCSA conveyances; §4 broadly bars claims/defenses based on aboriginal title	Affirmed: ANCSA §4(a) retroactively validates prior conveyances and precludes aboriginal-title defenses to RS 2477 grants
Scope of an RS 2477 right-of-way: limited to ingress/egress or broader highway-related uses (e.g., boat launches, camping, parking, day use)	RS 2477 conveys only the right of ingress and egress; other uses exceed the grant	RS 2477 allows any use consistent with public travel, including boat launches, camping, and day use	Reversed in part: RS 2477 is not limited to bare ingress/egress but is confined to "highway purposes" as of 1969; scope is a fact-specific inquiry (remand to determine whether particular proposed uses are reasonably necessary for highway purposes and whether they unreasonably interfere with the servient estate)

Paug-Vik, Inc. v. Wards Cove Packing Co., 633 P.2d 1015 (Alaska 1981) (ANCSA §4(a) treats prior conveyances as extinguishing aboriginal title and validates pre-ANCSA conveyances)
United States v. Atlantic Richfield Co., 612 F.2d 1132 (9th Cir. 1980) (ANCSA applies retroactively and extinguishes claims based on aboriginal title)
Dillingham Commercial Co. v. City of Dillingham, 705 P.2d 410 (Alaska 1985) (RS 2477 grants create easement-like rights of use; not a license to create parks or unrelated facilities)
Dickson v. State, Dep’t of Natural Resources, 433 P.3d 1075 (Alaska 2018) (once RS 2477 right-of-way is established, historic limited uses do not strictly confine future highway-consistent use)
Price v. Eastham, 75 P.3d 1051 (Alaska 2003) (describing RS 2477 as self-executing when a public highway is established)
Sierra Club v. Hodel, 848 F.2d 1068 (10th Cir. 1988) (RS 2477 rights limited to highway purposes; improvements must align with traditional uses and federal policy)
Southern Utah Wilderness Alliance v. Bureau of Land Management, 425 F.3d 735 (10th Cir. 2005) (federal law governs interpretation of RS 2477, but state law principles inform acceptance and scope; RS 2477 rights were "frozen" as of the repeal date)