## Facts

- The President issued a proclamation under the Antiquities Act of 1906 creating Jackson Hole National Monument in Teton County, Wyoming, from federally owned lands largely within the Teton National Forest, to be administered by the National Park Service.
- The proclamation stated the area contained historic landmarks and other objects of historic or scientific interest and reserved land for their protection.
- Wyoming sued Paul R. Franke, a Department of the Interior official, alleging the proclamation exceeded statutory authority and that federal officials were asserting control and jurisdiction over the area to the exclusion of the State.
- Wyoming claimed federal control would impair state interests in regulating fish and game (and related revenues), maintaining state highways within the area, collecting grazing-fee revenues, and taxing privately owned lands that federal officials allegedly threatened to acquire.
- The parties presented extensive evidence disputing whether the area contained qualifying objects of historic or scientific interest.
- Wyoming sought declaratory relief construing the Antiquities Act and proclamation and sought an injunction preventing federal management and control of the monument.

## Issues

1. Whether the Antiquities Act authorized the proclamation establishing Jackson Hole National Monument, including whether the area contained “objects of historic or scientific interest” and whether the reserved lands were within the statute’s limits.
2. Whether the President’s determinations under the Antiquities Act were subject to judicial review or were committed largely to executive discretion (including as a political question).
3. Whether the federal court had subject-matter jurisdiction, including satisfaction of the then-required amount in controversy.

## Decision

- The court dismissed Wyoming’s complaint and denied declaratory and injunctive relief.
- The court held the proclamation fell within the President’s delegated authority under the Antiquities Act.
- The court concluded the President’s discretionary determination that the area contained qualifying objects, and the choice of land to reserve, were not subject to judicial reexamination on the record presented absent a clear showing the proclamation was outside the statute.
- The court accepted that federal-question jurisdiction and the jurisdictional amount were satisfied, but ruled that the nature of the President’s discretion foreclosed the relief requested.

## Legal Principles

- The Antiquities Act delegates broad discretion to the President to identify objects of historic or scientific interest on federal lands and to reserve land needed for their protection.
- A presidential monument proclamation that conforms on its face to the Antiquities Act will not be set aside absent a clear showing the President acted outside statutory bounds; courts will not substitute their factual judgment for the President’s discretionary determination if it has a rational basis.
- Challenges focused on the scope, policy wisdom, or local economic effects of a monument designation generally present matters for Congress rather than grounds for judicial invalidation or injunctive relief.
- State regulatory and revenue interests (fish and game, highways, grazing fees, and taxation) do not by themselves defeat a lawful federal reservation and management decision made under delegated presidential authority.

## Conclusion

The court upheld the Jackson Hole National Monument proclamation as a valid exercise of presidential authority under the Antiquities Act and ruled that the President’s discretionary determinations supporting the designation were largely nonreviewable, requiring dismissal of Wyoming’s request for declaratory and injunctive relief.


State of Wyoming v. Franke, 58 F. Supp. 890 (D. Wyo. 1945)