590 U.S. 604
SCOTUS2020Background
- Atlantic Coast Pipeline sought to build a ~604‑mile natural‑gas pipeline crossing ~16 miles of the George Washington National Forest; Forest Service issued special‑use permits including a 0.1‑mile right‑of‑way ~600 ft below the Appalachian Trail.
- Respondents challenged the permit in the Fourth Circuit, arguing the Appalachian Trail is part of the National Park System and thus excluded from pipeline rights‑of‑way under the Mineral Leasing Act (30 U.S.C. §185).
- The Fourth Circuit vacated the permit, holding that the Interior Department’s delegation of Trail administration to the National Park Service (NPS) made the Trail "lands in the National Park System," so the Leasing Act barred Forest Service grants.
- Supreme Court granted certiorari to decide whether the Forest Service may grant pipeline rights‑of‑way across national forest lands traversed by the Appalachian Trail.
- The Court reversed: the Trails Act’s rights‑of‑way create an easement (nonpossessory interest) administered by NPS, but they do not convert the underlying federal land into land in the National Park System; therefore the Forest Service retained authority under the Leasing Act to grant the pipeline right‑of‑way.
Issues
| Issue | Respondents' Argument | Forest Service / Atlantic's Argument | Held |
|---|---|---|---|
| Whether the Appalachian Trail (and the lands it traverses) are "lands in the National Park System" such that the Leasing Act forbids pipeline rights‑of‑way there | NPS administers the Trail; the General Authorities Act/Organic Act define any "area of land... administered by the Secretary through the NPS" as Park System land, so the Trail and its corridor are Park System lands excluded from §185 | The Trails Act grants NPS only rights‑of‑way/easements to administer the Trail; easements do not transfer ownership or jurisdiction over the underlying land, so Forest Service retained jurisdiction and §185 authority | The Trail rights‑of‑way are easements; they do not convert the underlying national‑forest lands into National Park System lands; Forest Service may grant the pipeline right‑of‑way |
| Whether the Interior Department’s delegation of Trail administration to NPS (and subsequent statutory definitions) implicitly transferred jurisdiction/ownership of the underlying lands to NPS | Delegation + the Organic Act’s definition meant those Trail corridors became Park System units without explicit land‑transfer language | Delegation alone cannot override property/jurisdiction allocation absent clear congressional command; Trails Act uses "rights‑of‑way" not statutory land transfers and contains a proviso preserving other agencies’ management responsibilities | The administrative delegation did not effect a jurisdictional land transfer; Congress’ use of rights‑of‑way language and related provisions shows no intent to transfer land ownership/jurisdiction to NPS |
Key Cases Cited
- United States v. Detroit Timber & Lumber Co., 200 U.S. 321 (syllabus note on syllabus not part of the opinion)
(cited as background on issuance of syllabi) - New Mexico v. United States Trust Co., 172 U.S. 171 (1898)
(discusses difference between easement/right‑of‑way and ownership of land) - Marvin M. Brandt Revocable Trust v. United States, 572 U.S. 93 (2014)
(endorses use of common‑law easement principles in federal easement statutes) - Reves v. Ernst & Young, 507 U.S. 170 (1993)
(textualist principle: Congress’ word choice matters when altering statutory schemes) - Whitman v. American Trucking Assns., 531 U.S. 457 (2001)
(clear‑statement principle for major shifts in regulatory authority) - Gregory v. Ashcroft, 501 U.S. 452 (1991)
(principle requiring clear congressional statement before altering balance between federal/state power)