Sturgeon v. Frost

Sturgeon v. Frost refers to two cases heard by the Supreme Court of the United States, both dealing with the regulatory authority of the National Park Service over lands in Alaska under the Alaska National Interest Lands Conservation Act (ANILCA).[1] In the first case, Sturgeon v. Frost I, 577 U.S. ___ (2016), the Court ruled that the Park Service may only regulate "public" lands in Alaska, remanding the case back to the Ninth Circuit Appeals Court to decide whether the river in question (being "submerged land") is "public" or "non-public" land.[2] In Sturgeon v. Frost II, 587 U.S. ___ (2019), the Court unanimously ruled that ANILCA defines navigable waters in Alaska as "non-public" lands and that these are exempt from the National Park Service's national regulations.[3]

Sturgeon v. Frost I
Argued January 20, 2016
Decided March 22, 2016
Full case nameSturgeon v. Frost, Alaska Regional Director of the National Park Service, et al.
Docket no.14-1209
Citations577 U.S. ___ (more)
136 S. Ct. 1061; 194 L. Ed. 2d 108
Opinion announcementOpinion announcement
Case history
PriorSummary judgment granted, Sturgeon v. Masica, No. 3:11-cv-0183, 2013 WL 5888230 (D. Alaska Oct. 30, 2013); affirmed, 768 F.3d 1066 (9th Cir. 2014); cert. granted, 136 S. Ct. 27 (2015).
SubsequentOn remand, 872 F.3d 927 (9th Cir. 2017); cert. granted, 138 S. Ct. 2648 (2018).
Court membership
Chief Justice
John Roberts
Associate Justices
Anthony Kennedy · Clarence Thomas
Ruth Bader Ginsburg · Stephen Breyer
Samuel Alito · Sonia Sotomayor
Elena Kagan
Case opinion
MajorityRoberts, joined by unanimous
Laws applied
Alaska National Interest Lands Conservation Act, 16 U.S.C. § 3103(c)
Sturgeon v. Frost II
Argued November 5, 2018
Decided March 26, 2019
Full case nameSturgeon v. Frost, Alaska Regional Director of the National Park Service, et al.
Docket no.17-949
Citations587 U.S. ___ (more)
139 S. Ct. 1066; 203 L. Ed. 2d 453
Opinion announcementOpinion announcement
Case history
Prior872 F.3d 927 (9th Cir. 2017); cert. granted, 138 S. Ct. 2648 (2018).
Court membership
Chief Justice
John Roberts
Associate Justices
Clarence Thomas · Ruth Bader Ginsburg
Stephen Breyer · Samuel Alito
Sonia Sotomayor · Elena Kagan
Neil Gorsuch · Brett Kavanaugh
Case opinion
MajorityKagan, joined by unanimous
Laws applied
Alaska National Interest Lands Conservation Act, 16 U.S.C. § 3103(c)

Background

In establishing Alaska as a state, the United States government recognized the need to protect much of the land in the state but without superseding the state's own control of these lands. The Alaska National Interest Lands Conservation Act, passed in 1980, was designed to balance the federal and state interest in conservation. Effectively, the law designed a number of Conservation System Units (CSU)s that were designed as public land, and gave the National Park Service (NPS) the authority to manage the resources within the public lands within a CSU, and could not regulate non-public lands (including those owned by the state, tribes, and private parties). Such resources were read to include water resources within a public CSU. This was atop a law signed by President Jimmy Carter in 1976 that gave the Department of the Interior and through the NPS the authority to regulate conduct of navigable waters within federally designated national parks.

The case arose in 2007 when Alaskan hunter John Sturgeon was informed by the National Park Service that he could not pilot his hovercraft along the portion of the Nation River that fell within the Yukon–Charley Rivers National Preserve, one of the CSUs covered by ANILCA.[4] While Alaska state law allows for the use of hovercraft in navigable waters, the NPS had banned their use nationwide in public lands. Sturgeon filed a lawsuit in which he argued that section 103(c) of the ANILCA restricted the National Park Service's jurisdiction over portions of the river that were owned by the State of Alaska.[5] Sturgeon was backed by the state of Alaska, since the ruling affected how the state could enforce ANILCA. The United States District Court for the District of Alaska ruled in favor of the Park Service,[6] and the United States Court of Appeals for the Ninth Circuit affirmed.[7] The Ninth Circuit held that National Park Service regulations "applies to all federal-owned lands and waters administered by [the Park Service] nationwide, as well as all navigable waters lying within national parks", and thus the NPS could regulate activities along the whole of the navigable portion of the Nation River even if it fell outside the CSU.[8]

Sturgeon v. Frost I

Opinion of Court

In a unanimous opinion written by Chief Justice John Roberts, the Supreme Court reversed the Ninth Circuit's ruling.[9] Chief 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."[10] Rejecting the Ninth Circuit's conclusions, Chief Justice Roberts held that the Act directs the Park Service to regulate "non-public" lands in Alaska according to "Alaska-specific provisions".[11] Additionally, the Chief Justice wrote that "Section 103(c) draws a distinction between 'public' and 'non-public' lands within the boundaries of conservation system units in Alaska."[12] 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.[13] 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.[14]

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."[15]

Sturgeon v. Frost II

The Supreme Court remanded the case back to the Ninth Circuit for further review. In the second hearing, the Circuit Court determined that with the Nation River running through a federal reservation, the federal government had inherent water rights on the river, thus allowing the National Park Circuit's hovercraft ban to apply.[16] A second petition for writ was filed with the Supreme Court, arguing that this interpretation would mean that the federal government would have water rights on nearly any surface water running through federally-protected lands.[17]

The case was heard on November 5, 2018, and the Court issued its unanimous decision on March 26, 2019.[3] The Court reversed the Circuit Court's ruling, arguing that waterways were non-public lands, and that ANILCA stripped away any jurisdiction that the National Park Service had over these.[18]

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 v. Frost, No. 17-949, 587 U.S. ___ (2019).
  4. Sturgeon, slip op. at 1–6.
  5. Sturgeon, slip op. at 1–2, 6–7.
  6. Sturgeon v. Masica, No. 3:11-cv-00183 (D. Alaska Oct. 30, 2013).
  7. Sturgeon v. Masica, 768 F.3d 1066 (9th Cir. 2014).
  8. Sturgeon, slip op. at 11–12.
  9. Sturgeon, slip op. at 12–16.
  10. Sturgeon, slip op. at 12–14.
  11. Sturgeon, slip op. at 14.
  12. Sturgeon, slip op. at 14–15.
  13. Sturgeon, slip op. at 15–16.
  14. Sturgeon, slip op. at 16.
  15. Todd Henderson, Opinion analysis: A rebuke of the Ninth Circuit, and nothing more, SCOTUSblog (Mar. 23, 2016).
  16. Sturgeon v. Frost, 872 F.3d 927 (9th Cir. 2017).
  17. Zellmer, Sandi (October 29, 2018). "Argument preview: Can a hovercraft navigate the shoals of Yukon-Charley?". SCOTUSblog. Retrieved October 29, 2018.
  18. de Vogue, Ariane (March 26, 2019). "Alaska moose hunter can 'rev up his hovercraft,' Supreme Court rules". CNN. Retrieved March 26, 2019.
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