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Wilderness Watch v. Mainella

United States Court of Appeals for the Eleventh Circuit
375 F.3d 1085 (2004)


Facts

In 1964, Congress passed the Wilderness Act to protect certain lands in their natural condition. Once federal land has been designated as wilderness, the Wilderness Act significantly restricts the use of motorized vehicles on that land. A motor vehicle may only be used on wilderness land as necessary to administer the Wilderness Act protections. Cumberland Island received the wilderness designation. The National Park Service (defendant) continued to use motorized vehicles on the protected land. Wilderness Watch (plaintiff) sued the Park Service, asserting a violation of the Wilderness Act. At issue was the Park Service’s use of a 15-person van to shuttle tourists to Plum Orchard, a Park Services historical area just outside of the wilderness zone. Wilderness Watch wanted to stop the Park Service’s use of these vehicles. The Park Service claimed that it needed motorized access to meet its obligation to maintain the historic resources on the land. The Park Service further argued that because the Wilderness Act allowed wilderness land to be used for historical purposes, the Park Service was actually acting to further the goals of the Wilderness Act by driving tourists to promote and preserve historic resources. Finally, the Park Service argued that using a passenger van was essentially the same as driving any other motor vehicle, and, therefore, the Park Service’s use of the van was the same as the use that would be minimally necessary to administer the Wilderness Act in that area anyway. The trial court granted summary judgment in favor of the Park Service. Wilderness Watch appealed.

Rule of Law

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Issue

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Holding and Reasoning (Barkett, J.)

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  • A “yes” or “no” answer to the question framed in the issue section;
  • A summary of the majority or plurality opinion, using the CREAC method; and
  • The procedural disposition (e.g. reversed and remanded, affirmed, etc.).

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