Sturgeon v. Frost
136 S. Ct. 1061
SCOTUS2016Background
- John Sturgeon used a hovercraft on the Nation River, which flows through the Yukon-Charley Rivers National Preserve (a conservation system unit created by ANILCA). Alaska law allows hovercraft; Park Service regulations ban them.
- Park rangers ordered Sturgeon to remove his hovercraft; Sturgeon sued for declaratory and injunctive relief; Alaska intervened in his favor.
- The Park Service relied on authority to regulate "boating and other activities on or relating to water located within System units" (54 U.S.C. §100751(b)) and a national hovercraft ban (36 C.F.R. §1.2(a), §2.17(e)).
- ANILCA §103(c) distinguishes lands within conservation unit boundaries that are "public lands" (U.S. title) from "non-public" lands (state, Native corporation, private), and states that lands conveyed to the State/others shall not be subject to regulations "applicable solely to public lands within such units."
- The Ninth Circuit upheld enforcement of the hovercraft ban on the Nation River, reasoning §103(c) bars only Alaska‑specific regulations and permits nationally‑applicable Park Service regulations to apply to non‑public lands within unit boundaries.
- The Supreme Court granted certiorari, rejected the Ninth Circuit’s reading of §103(c), vacated and remanded, and expressly declined to decide whether the Nation River is "public land" or whether §100751(b) authorizes regulation of the river.
Issues
| Issue | Plaintiff's Argument (Sturgeon) | Defendant's Argument (Park Service / Ninth Cir.) | Held |
|---|---|---|---|
| Scope of ANILCA §103(c): does it permit Park Service to enforce nationally applicable regulations on non‑public lands within Alaska conservation unit boundaries? | §103(c) bars Park Service from treating non‑public (state) land as if federally owned; regulations tied to Park Service authority over federal lands (like the hovercraft ban) cannot be enforced on state waterways within units. | §103(c) only forbids regulations that apply "solely" to public lands in Alaska; broadly applicable national regulations (like the hovercraft rule) are not barred and may apply to non‑public lands within unit boundaries. | The Court rejected the Ninth Circuit’s interpretation that §103(c) allows nationwide Park Service rules to apply to non‑public lands in Alaska; that reading is inconsistent with ANILCA’s text and context. Vacated and remanded. |
| Whether §103(c) requires Alaska‑specific treatment of all lands within unit boundaries (public and non‑public) versus national rules applying uniformly | §103(c) supports Alaska‑specific distinctions; non‑public lands should not be regulated as if federal. | Nationally applicable regulations can apply uniformly, including to non‑public lands within Alaska units. | The Court held ANILCA contemplates Alaska‑specific treatment and rejected a reading that would force Alaska exceptions to be subordinate to nationwide rules; Ninth Cir.'s result would produce a counterintuitive "topsy‑turvy" scheme. |
| Whether the Nation River is "public land" under ANILCA (i.e., U.S. title or interest) | Nation River is state‑owned submerged land under the Alaska Statehood Act and thus not "public land" included in the unit. | The U.S. reserved an interest in waters within the unit (reserved water rights doctrine), so the United States holds title/interest making the river "public land." | The Court did not decide this question and remanded for the lower courts to address it in the first instance. |
| Whether §100751(b) independently authorizes regulation of activities on the Nation River even if it is non‑public | If the river is non‑public, ANILCA limits Park Service authority and §100751(b) cannot be used to regulate state land within Alaska units. | §100751(b) authorizes regulation of waters within System units, potentially independently of submerged‑land title; thus Park Service may regulate activities on the Nation River. | The Court did not decide whether §100751(b) authorizes regulation of Sturgeon’s activity on the Nation River and left the issue to the lower courts. |
Key Cases Cited
- United States v. California, 436 U.S. 32 (1978) (discusses transfer of title to submerged lands to states under the Submerged Lands Act)
- Cappaert v. United States, 426 U.S. 128 (1976) (establishes reserved water rights doctrine when federal government reserves land for a federal purpose)