Camfield v. United States

Under railroad land grants, Camfield and Drury (defendants) owned odd-numbered sections of land in a checkerboard pattern with federally owned even-numbered sections; they built a fence on their own odd-numbered parcels that, in combination with the checkerboard layout, completely enclosed the government's adjoining even-numbered sections. The United States (plaintiff) sued under the Unlawful Inclosures Act to compel removal, and the defendants argued gates allowed access to the public land, that their use furthered western development policy, and that banning fencing on private land would be unconstitutional; the circuit court and court of appeals both ruled for the United States, and the defendants appealed.