Sturgeon v. Frost

John Sturgeon, a moose hunter, was ordered by National Park Service rangers to stop using his hovercraft on the Nation River within the Yukon-Charley Rivers National Preserve in Alaska. The agency cited a nationwide ban on hovercraft use in all National Park System units. Sturgeon sued, arguing that the river was owned by the State of Alaska, not the federal government, and that under the Alaska National Interest Lands Conservation Act (ANILCA), the Park Service lacked regulatory authority over state-owned lands and navigable waters within national preserves. The Ninth Circuit ruled in favor of the Park Service. On March 22, 2016, the U.S. Supreme Court unanimously reversed, holding that ANILCA significantly limits the Park Service's jurisdiction in Alaska preserves and that the Ninth Circuit erred in applying ordinary national park rules. The case was remanded for further proceedings consistent with the Court's interpretation of ANILCA.

The U.S. Supreme Court unanimously (8-0) vacated the Ninth Circuit's judgment and remanded the case. Chief Justice Roberts delivered the opinion, holding that ANILCA establishes a different regulatory framework for Alaska preserves compared to ordinary national parks, and that the lower court failed to properly consider the statute's land-use restrictions on federal authority over state and private inholdings.

Whether the National Park Service may enforce its nationwide hovercraft ban on state-owned navigable waters within an Alaska national preserve established under ANILCA, or whether ANILCA's provisions limiting federal regulatory authority over non-federal lands preempt such enforcement.

The ruling was hailed as a significant victory for Alaska's sovereignty and for private property rights within federal conservation areas. It clarified that the federal government's regulatory power in Alaska's national preserves is more limited than in traditional national parks, reaffirming the state's authority over its own lands and navigable waters. The decision set a critical precedent limiting administrative agency overreach and eventually led to a second Supreme Court ruling in 2019 that unanimously affirmed Sturgeon's right to operate his hovercraft, cementing a lasting impact on federal-state land management relations in Alaska.