Sturgeon v. Frost

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Supreme Court of the United States
Sturgeon v. Frost
Term: 2018
Important Dates
Argument: November 5, 2018
Decided: March 26, 2019
Outcome
Reversed and remanded
Vote
9-0
Majority
Chief Justice John G. Roberts • Clarence Thomas • Ruth Bader Ginsburg • Stephen Breyer • Samuel Alito • Sonia Sotomayor • Elena Kagan • Neil Gorsuch • Brett Kavanaugh
Concurring
Sonia Sotomayor • Ruth Bader Ginsburg

Sturgeon v. Frost is a case argued before the Supreme Court of the United States on November 5, 2018, during the court's 2018-2019 term. The court reversed and remanded the ruling of the 9th U.S. Court of Appeals, holding that (1) Alaska's Nation River is not public land, (2) under the Alaska National Interest Lands Conservation Act of 1980 (ANILCA), non-public lands in Alaska are exempt from the National Park Service's regulatory authority, and (3) navigable waters in Alaska's national parks are also exempt from the Park Service's regulatory authority. The case came on a writ of certiorari to the United States Court of Appeals for the 9th Circuit.[1][2][3]

HIGHLIGHTS
  • The case: In 2007, National Park Service rangers told John Sturgeon that he could not operate his hovercraft on the Nation River because it was within the boundaries of Alaska’s Yukon-Charley National Preserve conservation unit. The National Park System prohibits hovercraft. Sturgeon then sued the Park Service. He said the State of Alaska owned the river and the Park Service could not enforce its hovercraft ban. The 9th Circuit Court ruled the Park Service’s hovercraft ban was legal because the ban applied nationwide. The Supreme Court then reversed the 9th Circuit’s decision and remanded the case. The 9th Circuit then ruled the waters of the Nation River were public lands under ANILCA and the parks service could regulate hovercraft use on the river.
  • The issue: "Whether the Alaska National Interest Lands Conservation Act prohibits the National Park Service from exercising regulatory control over State, Native Corporation, and private land physically located within the boundaries of the National Park System in Alaska."[4]
  • The outcome: The court reversed and remanded the ruling of the 9th U.S. Court of Appeals, holding that (1) Alaska's Nation River is not public land, (2) under ANILCA, non-public lands in Alaska are exempt from the National Park Service's regulatory authority, and (3) navigable waters in Alaska's national parks are also exempt from the Park Service's regulatory authority.[2][3]


    • You can review the lower court's opinion here.[5]

    Timeline

    The following timeline details key events in this case:

    • March 26, 2019: U.S. Supreme Court reversed and remanded the 9th Circuit's ruling
    • November 5, 2018: Oral argument
    • June 18, 2018: U.S. Supreme Court agreed to hear case
    • January 2, 2018: Petition filed with U.S. Supreme Court
    • October 2, 2017: The 9th Circuit Court "held, on remand from the Supreme Court, that the federal government properly exercised its authority to regulate hovercraft use on the rivers within conservation system units in Alaska.”[5]

    Background

    In 2007, National Park Service rangers told John Sturgeon that he could not operate his hovercraft on the Nation River because it was within the boundaries of Alaska’s Yukon-Charley National Preserve conservation unit. The National Park System prohibits hovercraft. Sturgeon then sued the Park Service. He said the State of Alaska owned the river and the Park Service could not enforce its hovercraft ban.[6][7]

    The 9th Circuit Court ruled the Park Service’s hovercraft ban was legal because the ban applied nationwide. The Supreme Court then reversed the 9th Circuit’s decision and remanded the case. The court held that the 9th Circuit incorrectly interpreted Section 103(c) of ANILCA. The 9th Circuit Court then ruled the waters of the Nation River were public lands under ANILCA and the parks service could regulate hovercraft use on the river. Sturgeon appealed to the U.S. Supreme Court and the court agreed to hear the case again on June 18, 2018.[8][6][7]

    According to SCOTUSblog, the decision could have impacted "the federal government’s authority to enforce regulations that restrict activities on navigable waters above riverbeds owned by a state. It is well settled that the Army Corps of Engineers, the Coast Guard, and even the U.S. Environmental Protection Agency have this power, which flows from specific delegations from Congress. But where does the Park Service fall in this cast of federal characters?"[9]

    In its ruling, the court emphasized that the Park Service has "multiple tools to 'protect' and 'preserve' rivers in Alaska’s national parks. ... While such authority might fall short of the Service’s usual power, it accords with ANILCA’s 'repeated[ ] recogni[tion]' that Alaska is 'the exception, not the rule.'"[3]

    Questions presented

    The petitioner presented the following questions to the court:[4]

    Questions presented:
    • Whether the Alaska National Interest Lands Conservation Act prohibits the National Park Service from exercising regulatory control over State, Native Corporation, and private land physically located within the boundaries of the National Park System in Alaska.

    Audio

    • Audio of oral argument:[10]

    Transcript

    • Transcript of oral argument:[11]

    Outcome

    Justice Elena Kagan delivered the opinion of the court. The court reversed and remanded the ruling of the 9th U.S. Court of Appeals, holding that (1) Alaska's Nation River is not public land, (2) under ANILCA, non-public lands in Alaska are exempt from the National Park Service's regulatory authority, and (3) navigable waters in Alaska's national parks are also exempt from the Park Service's regulatory authority.[2][3]

    Opinion

    In her opinion, Justice Kagan wrote:[3]

    “ The Park Service may not prevent John Sturgeon from driving his hovercraft on the Nation River. We held in an earlier part of this opinion that the Nation is not public land. See supra, at 12–15. And here we hold that it cannot be regulated as if it were. ... ANILCA recognized that when it came to navigable waters—just as to non-federal lands—in the new parks, Alaska should be "the exception, not the rule." Sturgeon I, 577 U. S., at ___ (slip op., at 14). Which is to say, exempt from the Park Service’s normal regulatory authority.[12] ”

    Concurring opinion

    Justice Sotomayor issued a concurring opinion, to which Justice Ginsburg joined. In her concurrence, Sotomayor wrote:[3]

    “ The Court’s opinion introduces limitations on—and thus could engender uncertainty regarding—the Service’s authority over navigable rivers that run through Alaska’s parks. If this is not what Congress intended, Congress should amend ANILCA to clarify the scope of the Service’s authority. ... In light of the explicit instructions throughout ANILCA that the Service must regulate and protect rivers in Alaska, I am convinced that Congress intended the Service to possess meaningful authority over those rivers. [12] ”

    Text of the opinion

    • Read the full opinion here.

    See also

    External links

    Footnotes

    1. ↑ Supreme Court of the United States, "17-949 Sturgeon v. Frost," accessed October 17, 2018
    2. ↑ 2.0 2.1 2.2 SCOTUSblog, "Sturgeon v. Frost," accessed March 28, 2019
    3. ↑ 3.0 3.1 3.2 3.3 3.4 3.5 Supreme Court of the United States, Sturgeon v. Frost, March 26, 2019
    4. ↑ 4.0 4.1 Supreme Court of the United States, "17-949 Sturgeon v. Frost," accessed October 17, 2018
    5. ↑ 5.0 5.1 SCOTUSblog, "Sturgeon v. Frost," accessed October 17, 2018
    6. ↑ 6.0 6.1 American Bar Association, "Sturgeon v. Frost: A little case in Alaska poses big questions for federalism," December 27, 2017
    7. ↑ 7.0 7.1 Oyez.org, "Sturgeon v. Frost," accessed October 17, 2018
    8. ↑ Supreme Court of the United States, Sturgeon v. Frost, March 22, 2016
    9. ↑ SCOTUSblog, "Argument preview: Can a hovercraft navigate the shoals of Yukon-Charley?" October 29, 2018
    10. ↑ Supreme Court of the United States, Sturgeon v. Frost, argued November 5, 2018
    11. ↑ Supreme Court of the United States, Sturgeon v. Frost, argued November 5, 2018
    12. ↑ 12.0 12.1 Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
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