Columbia River Gorge United-Protecting People and Property v. Yeutter

The Columbia River Gorge National Scenic Area Act (act) was enacted in 1986 to protect the economy and enhance the scenic, recreational, and natural resources of the gorge. The gorge was an area in Oregon and Washington bordering the Columbia River. Congress intended the act to preserve the beauty of the area for travelers who visited the mountains and lakes for recreation and to regulate competing activities within the scenic area, such as logging and fishing. As a partnership between the federal government, Oregon, and Washington, the act provided for interim management of the area by the secretary of agriculture (secretary) (defendant) and long-term management by the Columbia Gorge Commission (commission) (defendant). The commission was established by the Columbia River Gorge Compact (Columbia compact), a compact between the two states. Through the act, Congress consented in advance to the Columbia compact on the condition that the compact included certain provisions. Under the act and the Columbia compact, all private, federal, and local land use in the area would be governed by a management plan developed by the commission. Columbia River Gorge United-Protecting People and Property (United) (plaintiff) brought an action in federal district court against the secretary and the commission, alleging that the act violated the Commerce Clause and the Compact Clause of the United States Constitution. The district court rejected United’s claims and granted summary judgment to the secretary and the commission. United appealed.