Camfield v. United States

Congress granted millions of acres of land to railroads to encourage development in new states and territories. These grants typically consisted of odd-numbered sections of surveyed land, creating checkerboard patterns of ownership. Ranchers who purchased large tracts of land from the railroads often attempted to fence in adjacent public lands to monopolize their use. In 1893, Daniel Camfield and William Drury (defendants) constructed a fence on odd-numbered parcels of their land, with the completely enclosed even-numbered sections still owned by the United States (plaintiff). Congress had passed the Unlawful Inclosures Act (UIA) in 1885 to prevent obstructions that inhibited “free passage or transit over or through the public lands,” such as these fences. Under the authority of this statute, the United States sued the defendants in federal circuit court in Colorado to compel removal of the fence. The defendants responded that gates between the sections of land permitted access to the federal lands and that their use of the land furthered public policy encouraging development in the West. Additionally, the defendants argued that the UIA would be unconstitutional if interpreted to ban fencing on private property. The circuit court entered a decree in favor of the United States, and the court of appeals affirmed. The defendants appealed to the United States Supreme Court.