Friends of Shawangunks, Inc. v. Clark

A park commission bought a conservation easement over land bordering a lake using federal Land and Water Conservation Fund money, an easement that preserved scenic views and served as a buffer between the park and developed areas even though the public couldn't physically access it. After Marriott Corporation acquired an option to purchase the underlying land, the commission moved to amend the easement to let Marriott expand a golf course and increase water use, and the National Park Service told the commission no federal authorization was needed because this wasn't a "conversion" to non-public outdoor recreation uses under the Act. Friends of Shawangunks and others (plaintiffs) sued the Park Service and Interior Department (defendants); the district court agreed the amendment wasn't a conversion because the area wasn't publicly accessible, and the plaintiffs appealed.