## Facts

- John Sturgeon, an Alaska hunter, used a personal hovercraft for decades to travel on the Nation River to reach hunting areas.
- The Nation River flows through the Yukon-Charley Rivers National Preserve, a unit of the National Park System in Alaska.
- In 2007, National Park Service (NPS) rangers told Sturgeon that hovercrafts were prohibited within the preserve and warned he would be cited if he continued to use the hovercraft there.
- NPS relied on a regulation generally prohibiting hovercraft use on lands and waters within National Park System boundaries.
- The dispute turned on the Alaska National Interest Lands Conservation Act of 1980 (ANILCA), which created Alaska conservation system units but included substantial nonfederal “inholdings” within their boundaries.
- ANILCA § 103(c) provides that only “public lands” within unit boundaries are deemed part of the unit and that lands conveyed to the State, Native corporations, or private parties are not subject to regulations applicable solely to public lands within such units.
- ANILCA defines “public lands” as lands, waters, and interests therein to which the United States holds title.
- Sturgeon asserted the Nation River is navigable and therefore owned by Alaska, making it non-public land under ANILCA and outside NPS park-unit regulatory authority.

## Issues

1. Whether the Nation River within the Yukon-Charley Rivers National Preserve is “public land” under ANILCA § 103(c) and thus part of the preserve for purposes of NPS regulation.
2. If the river is not “public land,” whether NPS may nonetheless enforce its hovercraft prohibition on that river based on the regulation’s asserted nationwide character.

## Decision

- The Supreme Court unanimously reversed the Ninth Circuit.
- The Court held the Nation River is not “public land” under ANILCA because the United States does not hold title to it.
- The Court held ANILCA § 103(c) bars NPS from applying park-unit regulations, including the hovercraft prohibition, to nonfederal lands and waters (including state-owned navigable rivers) located within Alaska conservation system unit boundaries.
- The Court rejected the argument that NPS could apply the hovercraft prohibition to inholdings by characterizing it as a nationwide regulation rather than a unit-specific rule.

## Legal Principles

- Under ANILCA, “public lands” are determined by a title-based test: land or water is public only if the United States holds title.
- For navigable waters within a State, the riverbed (and associated ownership interests relevant here) generally belongs to the State; absent federal title, such waters are not ANILCA “public lands.”
- ANILCA § 103(c) creates a statutory boundary for NPS authority in Alaska: only federally owned parcels within a conservation system unit’s geographic boundaries are treated as part of the unit for purposes of regulations that apply because land is part of the Park System.
- A generally applicable NPS regulation cannot be used to impose park-unit regulatory control over Alaska inholdings when the regulation’s application depends on treating the inholding as part of the unit.
- A specific, later-enacted statute (ANILCA) limits otherwise broad, general agency authority (including NPS authority under its Organic Act) as to nonpublic lands within Alaska conservation system units.

## Conclusion

The Court held that because Alaska—not the United States—holds title to the navigable Nation River, the river is not “public land” under ANILCA, and ANILCA § 103(c) therefore prevents the National Park Service from enforcing park-based hovercraft restrictions on that state-owned river within the preserve’s boundaries.


Sturgeon v. Frost, 139 S. Ct. 1066 (2019)