That was added to a law signed by President Jimmy Carter in 1976 that gave the Department of the Interior and, through the NPS, the authority to regulate conduct of navigable waters within federally-designated national parks.

Sturgeon filed a lawsuit in which he argued that section 103(c) of the ANILCA restricted the National Park Service's jurisdiction over portions of the river that were owned by Alaska.

[8] In a unanimous opinion written by Chief Justice John Roberts, the Supreme Court reversed the Ninth Circuit's ruling.

"[10] Rejecting the Ninth Circuit's conclusions, Roberts held that the Act directs the Park Service to regulate "non-public" lands in Alaska according to "Alaska-specific provisions.

[13] To conduct further fact-finding with respect to those issues, the Supreme Court vacated the Ninth Circuit's ruling and remanded the case for further proceedings.