State of Utah v. Andrus
United States District Court for the District of Utah
486 F.Supp. 995 (1979)
Cotter Corporation (defendant), holding mining claims including a lease on Utah state school-trust land requiring access across federal BLM land, built access roads without notifying the BLM (plaintiff), which had separately designated the area a wilderness-study area under FLPMA; the BLM demanded Cotter cease road construction, Cotter refused, and the BLM sued, with Utah intervening to assert its own right to access the trust land. The parties disputed whether FLPMA Section 603(c)'s stricter wilderness-impairment standard (for uses commencing after October 1976) or its more lenient unnecessary-or-undue-degradation standard (for pre-1976 uses) applied to Cotter's road construction.
Whether the federal government may regulate public land to prevent the impairment of wilderness characteristics, as long as the regulation avoids prohibiting an easement or existing land uses.