Andrus v. Utah
446 U.S. 500 (1980)

  • When Utah became a State, the Utah Enabling Act of 1894 said that the Federal government would divvy up Utah's land into townships, and that each township would be further divvied into numbered lots. Utah would take title to lots 2, 16, 32, and 36 of each township in order to build schools, jails, city halls, etc. and the rest would remain in Federal hands.
    • The Federally-owned lots would be sold to private individuals, or retained by the Federal government for military bases, national forests, etc.
    • This sort of deal was standard for most States as they entered the Union.
  • The Utah Enabling Act further stipulated that if any of the lots due to the State had already been sold off to someone else (or were needed by the Federal government for something), then the State could take an equal amount of other land "to be selected within the State in such a manner as its legislature may provide with the approval of the Secretary of the Interior.
    • That is known as indemnity lands (or in lieu lands).
  • Utah didn't get around to deciding which lands it wanted until 1965. They chose 194 lots in an area that was a Federal grazing district.
    • 'Grazing districts' were created by the Taylor Grazing Act (43 U.S.C. 315).
      • The Taylor Grazing Act gave the Secretary of the Interior significant discretion on how Federal lands were to be sold or otherwise disposed of. It required all Federal lands to have a designation, and required people to have a permit in order to enter them.
        • It was a response to the environmental problems caused by overgrazing on Federal lands.
    • The land Utah wanted just also happened to contain a lot of oil, and was worth a lot of money. Way more money that the 194 lots Utah had given up was worth.
      • What a coincidence!
  • The Secretary of the Interior rejected Utah's application. Utah sued.
    • The Secretary argued that 7 of the Taylor Grazing Act prevented him from approving land transfers that were of "grossly disparate value."
  • The Trial Court found for Utah and told DOI to approve the transfer. DOI appealed.
  • The Appellate Court affirmed. DOI appealed.
    • The Appellate Court found that Utah had a right to select indemnity land of equal acreage without regard to the relative values of the original school land grants and the indemnity selections.
  • The US Supreme Court reversed.
    • The US Supreme Court found that 7 gave DOI the authority to use broad discretion, and "grossly disparate value" was a valid ground for refusing to accept Utah's selections.
      • That's pretty broad discretion.
    • The Court found that Congress' purpose in authorizing indemnity lands was to give States a rough equivalent of the school land grants in place that were lost through preemption or private entry prior to survey.
    • The Court found that the Utah Enabling Act used the word equivalent. That could be interpreted as meaning "equivalent size" or "equivalent value". Since it was ambiguous, the Secretary of Interior was allowed to interpret it.
      • See Chevron U.S.A. Inc. v. Natural Resources Defense Council (467 U.S. 837 (1984)).
  • In a dissent it was argued that the bilateral compact under which Utah joined the Union was a big deal and a binding contract, and there was no way that Congress meant to breach that compact with minor legislation such as the Taylor Grazing Act.