In the case of Sturgeon v. Frost, 2018, John Sturgeon challenged the National Park Service's (NPS) authority to enforce its hovercraft ban on a river within Alaska’s Yukon-Charley Rivers National Preserve where he was hunting moose. The Supreme Court ruled in favor of Sturgeon stating that NPS did not have the power to regulate activities on navigable waters lying within national parks in Alaska because it violated provisions of the Alaska National Interest Lands Conservation Act (ANILCA). ANILCA limits federal regulation over state-owned lands physically located within federally designated conservation system units. This ruling clarified that rivers are considered public lands and thus subject to state jurisdiction if they run through federal preserves.

In the dissenting opinion for Sturgeon v. Frost, Justice Sonia Sotomayor argued that the majority's interpretation of Alaska National Interest Lands Conservation Act (ANILCA) was incorrect and overly broad. She contended that ANILCA did not intend to deprive the National Park Service of its authority over navigable waters within park boundaries in Alaska. Instead, she believed it aimed to prevent new land withdrawals without Congressional approval while maintaining existing regulatory frameworks. The majority’s decision, according to her view, could undermine federal management rights on public lands across America by setting a precedent where state law trumps federal regulations on federally owned waterways or properties located within conservation system units but are subject to non-federal ownership.