## Facts

- Congress enacted the Boundary Waters Canoe Area Wilderness Act of 1978, regulating use within the Boundary Waters Canoe Area Wilderness (BWCAW), a unit of the Superior National Forest along the Minnesota–Canada border.
- The BWCAW covered about 1,075,000 acres of land and waterways with mixed ownership: the United States owned nearly 90% of the land; Minnesota owned about 121,000 acres and held title to beds beneath substantial navigable waters; private owners held additional inholdings.
- Section 4 restricted motorboats to limited lakes and confined snowmobiles to designated routes and areas, expressly applying within the BWCAW boundaries, including some state-owned waters and nonfederal lands.
- The statute acknowledged Minnesota’s jurisdiction over waters but prohibited the state from regulating less stringently than the federal scheme within the BWCAW.
- Minnesota, landowner and user groups, and related entities filed three suits challenging multiple provisions of the Act on constitutional, statutory, and treaty grounds.
- The district court granted summary judgment for the United States and intervenor conservation organizations, upholding all challenged provisions.
- The Eighth Circuit consolidated the appeals, addressing (1) the Property Clause challenge to regulation of nonfederal lands and waters and (2) remaining constitutional, statutory, and treaty challenges.

## Issues

1. Whether Congress, under the Property Clause, may regulate motorboat and snowmobile use on state-owned waters and other nonfederal property within the BWCAW when necessary to protect federal lands and their designated wilderness purposes.
2. Whether the Act’s other restrictions violated constitutional protections (including due process, equal protection, or takings principles) or were invalid due to conflicts with prior federal statutes or treaties.

## Decision

- The Eighth Circuit affirmed the district court’s summary judgment, upholding the Act against all challenges.
- The court held Congress acted within the Property Clause in extending motorboat and snowmobile limits to state-owned waters and other nonfederal property within the BWCAW where such use would interfere with federal wilderness purposes.
- The court rejected the remaining constitutional, statutory, and treaty claims and sustained the Act as a valid, comprehensive federal regulatory scheme for the BWCAW.

## Legal Principles

- Congress’s Property Clause authority over federal lands includes power to enact reasonable regulations reaching off-federal conduct when that conduct threatens or substantially affects federal lands and the purposes for which Congress reserved them.
- State ownership or jurisdiction over navigable waters and submerged lands does not bar Congress from imposing use restrictions tied to protecting adjacent or intermingled federal lands within a federal reservation.
- In evaluating broad wilderness-management legislation, courts will uphold restrictions rationally related to preserving the designated character and uses of the federal area, and facial challenges alleging takings or generalized constitutional violations will fail absent a showing that the statutory scheme is constitutionally infirm.

## Conclusion

The Eighth Circuit sustained the BWCAW Act’s motorboat and snowmobile restrictions as a valid exercise of Congress’s Property Clause power, including application to state-owned waters and other nonfederal property within the wilderness area when necessary to protect federal lands and their congressionally designated purposes, and it rejected all additional constitutional, statutory, and treaty challenges.


Minnesota v. Block, 660 F.2d 1240 (8th Cir. 1981)