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
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
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
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