The case of Sturgeon v. Frost in 2015 revolved around the issue of whether the National Park Service (NPS) could enforce its regulations on state-owned lands and navigable waters within federally managed conservation areas in Alaska. John Sturgeon, an Alaskan moose hunter, was prohibited by NPS from using his hovercraft to travel a river that ran through both federal and state land due to NPS rules banning such vehicles. The Supreme Court ruled unanimously in favor of Sturgeon, stating that the Alaska National Interest Lands Conservation Act (ANILCA) exempted public lands in Alaska from certain standard regulatory provisions unless those lands were explicitly owned by the Federal Government. Therefore, it concluded that NPS did not have authority over state-owned rivers running through national parks or preserves.

In the dissenting opinion for Sturgeon v. Frost, Justice Sonia Sotomayor argued that the National Park Service has authority over navigable waters within Alaska's national parks and can enforce its regulations on those waters. She contended that both the Alaska National Interest Lands Conservation Act (ANILCA) and previous legal precedents support this view. The majority interpretation of ANILCA, she believed, was too narrow and failed to consider Congress’s intent to protect natural resources in these areas from harmful activities such as hovercraft use. Furthermore, she disagreed with the majority's assertion that state sovereignty principles were violated by federal regulation of Alaskan waterways within national parks.