## Facts

- Private landowners owned recreational/resort property on the northern shore of Crooked Lake in Michigan and claimed riparian rights to reasonable use of the lake’s surface under Michigan law.
- About 95% of Crooked Lake’s shoreline lay within the congressionally designated Sylvania Wilderness inside the Ottawa National Forest; the United States owned most surrounding lands and was also a riparian owner.
- Congress enacted the Wilderness Act and later designated the Sylvania Wilderness through the Michigan Wilderness Act, directing federal agencies to preserve wilderness character and leaving areas unimpaired for future wilderness use.
- In 1992 the Forest Service adopted Amendment No. 1 to the Ottawa National Forest plan, applying to the wilderness portion of Crooked Lake and prohibiting sailboats, houseboats, and certain nonburnable disposable food and beverage containers.
- Landowners sought judicial review, alleging the restrictions exceeded federal authority under the Property Clause and unlawfully interfered with their state-law riparian rights; a Fifth Amendment takings claim was bifurcated and not decided in the challenged merits ruling.
- The district court upheld Amendment No. 1 on summary judgment (reserving takings issues), and the landowners appealed.

## Issues

1. Whether Congress’s Property Clause power, as implemented through the Wilderness Act and Michigan Wilderness Act, authorized the Forest Service to regulate surface uses of Crooked Lake affecting the adjacent federal wilderness.
2. Whether “valid existing rights” language in the wilderness statutes barred or limited federal regulation that constrained private riparian uses recognized by state law.
3. Whether the challenged restrictions unlawfully infringed Michigan riparian rights, which are defined as rights of reasonable use.

## Decision

- The Sixth Circuit affirmed the district court’s judgment upholding Amendment No. 1.
- The court held that the Property Clause permitted regulation of lake-surface activities shared with private owners when reasonably related to protecting federal wilderness lands.
- The Wilderness Act and Michigan Wilderness Act were read to delegate sufficient authority to the Forest Service to impose the vessel and container restrictions to preserve wilderness character.
- The “valid existing rights” provisions did not immunize private riparian rights from reasonable federal regulation consistent with statutory purposes.
- Under Michigan law, riparian rights are limited to reasonable use and remain subject to regulation; the restrictions affected certain recreational choices but did not eliminate essential access or constitute a total deprivation of use.

## Legal Principles

- Congress may regulate conduct on nonfederal property under the Property Clause when the regulation is reasonably related to protecting federal property and its designated uses.
- Federal wilderness statutes may confer broad administrative discretion to restrict activities to preserve wilderness character and prevent impairment.
- “Valid existing rights” clauses preserve the existence of state-law property interests but do not freeze them against reasonable regulation that serves valid federal objectives.
- Michigan riparian rights are rights of reasonable use of the water’s surface, not absolute entitlements to particular recreational or commercial uses.
- Regulations that leave meaningful access and continued reasonable use generally do not amount to abrogation of riparian ownership for purposes of the statutory and riparian-rights analysis (separate takings questions may remain).

## Conclusion

The court upheld Forest Service restrictions on sailboats, houseboats, and certain disposable containers within a federally designated wilderness lake area, concluding that Congress’s Property Clause authority and the wilderness statutes supported the regulations and that the limits were consistent with Michigan’s reasonable-use conception of riparian rights.


Stupak-Thrall v. United States, 70 F.3d 881 (6th Cir. 1995)