Sturgeon v. Frost
In brief
John Sturgeon won: the Court said the Park Service could not regulate the Nation River as ordinary federal parkland and overturned the Ninth Circuit.
- Where it stands
- Decided
Decided 9-0 · March 26, 2019 · Opinion by Justice Kagan
- What it’s about
- The Supreme Court overturned the Ninth Circuit’s ruling and sent the case back to the lower court (reversed and remanded), deciding that Alaska’s Nation River is not “public land” under the Alaska National Interest Lands Conservation Act (ANILCA).
- Who it affects
- The decision means the National Park Service cannot use its ordinary park rules to regulate navigable waters and other nonfederal land within Alaska park boundaries as if they were federal parkland.
Summary: written with AI from the case record.
What it's about
Because the river and other nonfederal lands inside Alaska’s national parks are outside those park units for this law, the National Park Service cannot apply its usual national-park rules there.
The case concerns Congress's special rules for Alaska parks, where state, Native Corporation, and private property can lie inside a park's mapped boundaries.
Question presented
Whether the Alaska National Interest Lands Conservation Act prohibits the National Park Service from exercising regulatory control over State, Native Corporation, and private land physically located within the boundaries of the National Park System in Alaska.
What the Court decided
Holding
1. The Nation River is not public land for purposes of ANILCA. “[P]ublic land” under ANILCA means (almost all) “lands, waters, and interests therein” the “title to which is in the United States.” 16 U. S. C. §3102(1)–(3). Because running waters cannot be owned, the United States does not have “title” to the Nation River in the ordinary sense. And under the Submerged Lands Act, it is the State of Alaska—not the United States—that holds “title to and ownership of the lands beneath [the River’s] navigable waters.” 43 U. S. C. §1311. 2. Non-public lands within Alaska’s national parks are exempt from the Park Service’s ordinary regulatory authority. Section 103(c) arose out of concern from the State, Native Corporations, and private individuals that ANILCA’s broadly drawn boundaries might subject their properties to Park Service rules. Section 103(c)’s first sentence therefore sets out which land within those new parks qualify as parkland—“[o]nly” the “public lands” within any system unit’s boundaries are “deemed” a part of that unit. By negative implication, non-public lands are “deemed” outside the unit. In other words, non-federally owned lands inside system units (on a map) are declared outside them (for the law). 3. Navigable waters within Alaska’s national parks—no less than other non-public lands—are exempt from the Park Service’s normal regulatory authority. The Service argues that, if nothing else, ANILCA must at least allow it to regulate navigable waters. The Act, however, does not readily allow the decoupling of navigable waters from other non-federally owned areas in Alaskan national parks. 872 F. 3d 927, reversed and remanded.
- Result
- Reversed
The vote
What's next
The case returned to the lower court for further proceedings consistent with the Supreme Court's ruling. The Supreme Court has finished its action on this docket.
Documents
Docket activity
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More questions
- What did the Court decide in Sturgeon v. Frost?
- The Court said the Nation River is not public land under ANILCA. It overturned the Ninth Circuit and sent the case back.
- Why could the Park Service not regulate the Nation River normally?
- The Court said Alaska owns the land beneath the River's navigable waters. ANILCA treats nonfederal areas within Alaska park boundaries as outside the park for ordinary Park Service regulation.
- Who won Sturgeon v. Frost?
- John Sturgeon won at the Supreme Court. The Court unanimously overturned the Ninth Circuit's ruling.
- What happens next in Sturgeon v. Frost?
- The lower court must handle the case under the Supreme Court's interpretation of ANILCA. The Supreme Court has completed this docket action.
Sources
Primary materials plus reporting. Best-effort analysis: this explainer relies on a mix of primary materials and trusted secondary sources. Official filings and opinions remain authoritative.