State of Wyoming v. Franke

The Antiquities Act of 1906 (the act) granted the president the discretion to designate objects of historic or scientific interest as national monuments. Pursuant to the act, President Franklin D. Roosevelt issued a proclamation that established the Teton National Forest area in the State of Wyoming (plaintiff) as a national monument named Jackson Hole National Monument (the monument). The monument was to be controlled by the National Park Service under the direction of the secretary of the United States Department of the Interior (defendant). President Roosevelt justified the establishment of the monument by referring to the historic landmarks and other objects of historic and scientific significance within the Teton National Forest. The State of Wyoming opposed the designation of the area as a national monument. The state was opposed, in part, because the state derived a large income from fishing and hunting activities and grazing fees in the area. After the designation, the governor of Wyoming threatened to use law enforcement to prevent federal officials from taking control of the monument. The State of Wyoming sued the secretary of the Interior, claiming that the proclamation establishing the monument was not authorized by the act and that the secretary of the Interior had no right to control the area in which the monument was established. Both the state and federal government presented evidence on the issue of whether the area, in fact, had historic or scientific interest, as indicated in the proclamation. Wyoming sought an injunction to prevent the secretary of the Interior from asserting control over the monument.