National Audubon Society v. Hodel
606 F.Supp. 825 (D.Alaska 1984)

  • 1302 of the Alaska National Interest Lands Conservation Act (ANILCA) allows for the Department of the Interior (DOI) to trade Federal-owned lands for private lands.
    • 1302(h) requires that the lands DOI gets will further the purpose of ANILCA, and that the exchanges must further the public interest if the lands exchanged are of unequal value.
  • DOI entered into an agreement with several Alaska Native Corporations (aka CIRI Group) to transfer a Federally-owned island (St. Matthews Island) in the Alaska Maritime National Wildlife Refuge for some land near some other Alaskan wildlife refuges.
    • CIRI Group wanted the island to drill for oil off the Alaskan coast.
      • The island was very valuable for the oil companies.
    • The land CIRI Group was offering in return for St. Matthews Island was already protected from development by easements.
      • The lands were not worth very much.
  • DOI made a determination that the land exchange met the requirements of 1302(h).
  • Environmental groups (led by NAS) sued for an injunction.
    • NAS argued that the transfer was not in the public interest, and therefore impermissible under 1302(h).
    • NAS argued that they had standing because St. Matthew's Island was a stopping point for migratory seabirds, and if it was ruined, the NAS members wouldn't be able to see those pretty birds at other stopping points on their migratory route.
  • The Trial Court found for NAS and issued the injunction.
    • The Trial Court found that the land DOI was acquiring from CIRI Group was already protected, so there was no net gain to DOI in acquiring it.
      • Meanwhile, turning St. Matthews Island into an oil shipping hub would significantly degrade the environment.
    • The Court found that DOI had not adequately weighed the costs and benefits of the land transfer. Therefore they had not met the requirements of 1302(h) and so an injunction was warranted.
    • The Court chose not to give discretion to DOI and defer to their judgment of the comparative value of the lands.