Amazing! Especially since Roberts wrote it...
Held: The Ninth Circuit’s interpretation of Section 103(c) is inconsistent
with both the text and context of ANILCA. Pp. 12–16.
(a) 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. Pp. 12–
14.
(b) Moreover, it is clear that Section 103(c) draws a distinction
between “public” and “non-public” lands within the boundaries of
conservation system units in Alaska. And yet, according to the court
below, if the Park Service wanted to differentiate between that “public”
and “non-public” land in an Alaska-specific way, it would have to
regulate the “non-public” land pursuant to rules applicable outside
Alaska, and the “public” land pursuant to Alaska-specific provisions.
Assuming the Park Service has authority over “non-public” land in
Alaska (an issue the Court does not decide), the Court concludes that
this is an implausible reading of the statute. The Court therefore rejects
the interpretation of Section 103(c) adopted by the court below.
Pp. 14–15.
(c) The Court does not reach the remainder of the parties’ arguments.
In particular, it does not decide whether the Nation River
qualifies as “public land” for purposes of ANILCA. It also does not
decide whether the Park Service has authority under Section
100751(b) to regulate Sturgeon’s activities on the Nation River, even
if the river is not “public” land, or whether—as Sturgeon argues—any
such authority is limited by ANILCA. Finally, the Court does not
consider whether the Park Service has authority under ANILCA over
both “public” and “non-public” lands within the boundaries of conservation
system units in Alaska, to the extent a regulation is written to
apply specifically to both types of land. The Court leaves those arguments
to the lower courts for consideration as necessary. Pp. 15–
16.
768 F. 3d 1066, vacated and remanded.
