Sturgeon v. Frost

For forty years, John Sturgeon (plaintiff) had used his hovercraft to hunt moose along a portion of the Nation River in Alaska that flowed through the Yukon-Charley Rivers National Preserve. The preserve was a unit of the federal park system managed by the National Park Service (the park service) (defendant). The park service issued a regulation prohibiting the use of hovercraft on rivers within any federal preserve or park, and park rangers informed Sturgeon that he could no longer use his hovercraft in the preserve. Sturgeon challenged the validity of the regulation, arguing that the Alaska National Interest Lands Conservation Act of 1980 (ANILCA) created a special rule prohibiting the park service from regulating land within national parks in Alaska that was not federally owned. Sturgeon asserted that because the Nation River was owned by Alaska and not by the federal government and that thus the park service was not authorized to ban hovercraft use on the river. The district court found that, because the hovercraft ban was a nationwide rule, ANILCA did not preclude its enforcement in Alaska. The United States Court of Appeals for the Ninth Circuit affirmed. The United States Supreme Court disagreed with the lower courts’ reasoning and therefore reversed and remanded the matter to the Ninth Circuit for further consideration. On remand, the Ninth Circuit found that the Nation River was public land for purposes of ANILCA and that the park service was authorized to regulate hovercraft use on the river. The United States Supreme Court reviewed the Ninth Circuit’s judgment.