Defenders of Wildlife v. Hull

Arizona (defendant) was admitted to the Union in 1912. In 1987, the Arizona legislature passed House Bill 2017, which attempted to relinquish the state’s title in most of the bedlands of Arizona’s waterways. However, in 1991, an Arizona appellate-court decision determined that parts of House Bill 2017 that relinquished title in many submerged lands of Arizona’s waterways violated the public-trust doctrine. The court held that such lands were held in trust for the public and that the state had a fiduciary duty to maintain the lands for public benefit. In 1992, in response, the Arizona legislature passed additional legislation that established the Arizona Navigable Stream Adjudication Commission (the commission). The commission was charged with issuing determinations regarding the navigability of the state’s waterways for purposes of disclaiming the state’s title to certain bedlands along waterways. In 1998, based on the commission’s determinations, the Arizona legislature passed Senate Bill 1126, which disclaimed the state’s title to certain land along several rivers that were navigable at the time of Arizona’s admission to the Union. Subsequently, Governor Hull (defendant) signed Senate Bill 1126 into law. Soon after, the Defenders of Wildlife (plaintiff) sued Governor Hull and the State of Arizona, claiming that Senate Bill 1126 violated the public-trust doctrine. The state agreed that Senate Bill 1126 violated the public-trust doctrine, but Governor Hull did not. The trial court granted summary judgment in favor of Governor Hull. The Defenders of Wildlife and the state appealed.