Light v. United States
1911 U.S. LEXIS 1696, 31 S. Ct. 485, 220 U.S. 523 (1911)
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Rule of Law:
The federal government has the power under the Property Clause to regulate its public lands, and this authority is not constrained by state fence laws, especially when a property owner engages in willful trespass by intentionally allowing livestock to graze on federal property.
Facts:
- The Secretary of Agriculture, under authority granted by Congress, established regulations requiring permits for grazing livestock in federal forest reserves.
- Fred Light owned cattle and pastured them on open public land adjacent to the unfenced Holy Cross Forest Reserve in Colorado.
- Light turned his cattle out at a time and place where he knew and intended for them to leave the public lands and enter the Reserve to access its superior water and pasturage.
- Light did not obtain the federally required permit to graze his cattle on the Reserve.
- When notified by federal authorities to remove his cattle from the Reserve, Light refused and threatened to resist any attempt by a forest officer to do so.
- Light asserted that under Colorado law, the government had no legal remedy because it had not enclosed the Forest Reserve with a fence.
Procedural Posture:
- The United States filed a suit in federal court seeking an injunction against the defendant to prevent him from pasturing his cattle on the Holy Cross Forest Reserve.
- The trial court found for the United States and issued the injunction.
- The defendant appealed the trial court's decision, bringing the case before the Supreme Court of the United States.
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Issue:
Does a state law that prevents a landowner from recovering damages for trespass by animals unless the property is fenced preclude the federal government from obtaining an injunction to stop a cattle owner from intentionally pasturing his cattle on an unfenced federal forest reserve?
Opinions:
Majority - Mr. Justice Lamar
No. A state's fence law does not prevent the federal government from enjoining a willful trespass onto its lands. The United States possesses the rights of an ordinary proprietor over its property and may regulate its use under the Property Clause of the Constitution. While an implied license historically allowed grazing on the open public domain, the government can revoke this license at any time, which it effectively did by creating the forest reserve. State fence laws are intended to condone accidental trespasses by straying cattle, not to authorize willful trespass. Light's act of turning out his cattle with the expectation and intent that they would enter the Reserve was equivalent to driving them onto the property, constituting a willful trespass that the government is entitled to enjoin, regardless of the absence of a fence.
Analysis:
This decision solidifies the principle of federal supremacy over the management of federal lands under the Property Clause. It clarifies that the federal government's rights as a landowner are not subordinate to state property laws, such as fence-out statutes. The case distinguishes between accidental straying of livestock, which state laws might address, and intentional or willful trespass, against which a landowner (including the government) has a right to protection. This ruling empowers federal agencies to regulate and protect public lands from unauthorized use without the prohibitive expense and logistical impossibility of fencing vast territories.
