Summary
The Supreme Court held that the Alaska National Interest Lands Conservation Act (ANILCA) §103(c) exempts non-public lands—including state-owned navigable waters—within Alaska’s national park boundaries from the National Park Service’s ordinary regulatory authority. The Nation River, to which the United States holds only a reserved water right, is not “public land” under ANILCA, and the hovercraft ban cannot be enforced there. Section 103(c) deems inholdings (state, Native, and private lands) outside the park for legal purposes, limiting the Service’s regulations to federally owned lands and waters. This Alaska-specific exception reflects Congress’s intent to balance conservation with local control over non-federal property within the state’s uniquely drawn park boundaries.