Statutory Interpretation

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Supreme Court of the United States

Case Name: Sturgeon v. Frost

Case No.: 14-1209

Focus: Statutory Interpretation

9^th Circuit interpretation of Section 103(c) of ANILCA is inconsistent with the text and context of the ANILCA.

“The Ninth Circuit’s interpretation of Section 103(c) violates “a fundamental canon of statutory construction that the words of a statute must be read in their context and with a view to their place in the overall statutory scheme,” Roberts v. Sea-Land Services, Inc., 566 U. S. ___, ___. ANILCA repeatedly recognizes that Alaska is different, and ANILCA itself accordingly carves out numerous Alaskaspecific exceptions to the Park Service’s general authority over federally managed preservation areas. Those Alaska-specific provisions reflect the simple truth that Alaska is often the exception, not the rule. Yet the reading below would prevent the Park Service from recognizing Alaska’s unique conditions. Under that reading, the Park Service could regulate “non-public” lands in Alaska only through rules applicable outside Alaska as well. The Court concludes that, whatever the reach of the Park Service’s authority under ANILCA, Section 103(c) did not adopt such a “topsy-turvy” approach.”

Vacated and Remanded

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Attorney Derek A. Hawkins is the managing partner at Hawkins Law Offices LLC, where he heads up the firm’s startup law practice. He specializes in business formation, corporate governance, intellectual property protection, private equity and venture capital funding and mergers & acquisitions. Check out the website at www.hawkins-lawoffices.com or contact them at 262-737-8825.