Access For the Everyman

Introduction 

Across the American west, millions of acres of public lands are inaccessible to public use, through the blocking by surrounding private properties. This entrapped public land is referred to as “landlocked.” For various reasons, over 9.52 million acres are blocked from access by reasonable means or efforts (TRCP, 2018). Some parcels are trapped for reasons having to do with the storied past of land laws and acts in the American West; while other parcels have been purposefully entrapped by individuals buying surrounding plots with the intention to completely exclude public access. The father of conservation and America's public lands, President Theodor Roosevelt, said “Wild beasts and birds are by right not the property merely of the people today, but the property of the unborn generations, whose belongings we have no right to squander” (Roosevelt,1903).  President Roosevelt placed importance on the preservation, conservation, and enjoyment of our nation's land for the use by everyone. This is a founding principle and unalienable right of the American people and it is being taken away. Every American is an owner of public land, one of the great resources and benefits this country has to offer. The intentional or otherwise entrapment of the American people's land for the sole use of a few individuals is wrong and needs to be amended. Changes in legislation, the addition of easements, and the installation of fence ladders are solutions that bring access back to America's lands for the American people. Every public parcel should be accessible to those who are willing to put the effort into traveling there.

Introduction 

Across the American west, millions of acres of public lands are inaccessible to public use, through the blocking by surrounding private properties. This entrapped public land is referred to as “landlocked.” For various reasons, over 9.52 million acres are blocked from access by reasonable means or efforts (TRCP, 2018). Some parcels are trapped for reasons having to do with the storied past of land laws and acts in the America west; while other parcels have been purposefully entrapped by individuals buying surrounding plots with the intention to completely exclude public access. The father of conservation and America's public lands, President Theodor Roosevelt, said “Wild beasts and birds are by right not the property merely of the people today, but the property of the unborn generations, whose belongings we have no right to squander” (Roosevelt,1903).  President Roosevelt placed importance on the preservation, conservation, and enjoyment of our nation's land for the use by everyone. This is a founding principle and unalienable right of the American people and it is being taken away. Every American is an owner of public land, one of the great resources and benefits this country has to offer. The intentional or otherwise entrapment of the American people's land for the sole use of a few individuals is wrong and needs to be amended. Changes in legislation, the addition of easements, and the installation of fence ladders are solutions that bring access back to America's lands for the American people. Every public parcel should be accessible to those who are willing to put the effort into traveling there.

The Storied Past of Private Land in the American West

The history of land in the American West has a storied and complex past. There are several important events that need to be known in order to understand how our private and public lands have reached the state they are in today. The year 1862 was a monumentally influential one for western expansion. First, on May 20th, the Homestead Act was signed into law by President Lincoln giving any American citizen that was a leader of a household, man or woman and/or at least 21 years of age, the right to claim a 160-acre plot west of the Mississippi River in any place they saw fit (Homestead Act, 1862). There were several requirements for the newfound homesteaders in order to earn and keep the rights to their land. Firstly, they had to make efforts towards meaningful improvements, build a home, attempt to farm, and inhabit the land for a minimum of five years. At the end of those five years, if those actions had been completed, the government gifted the homesteaders the land free of charge leaving the individual to only pay a small registration fee (Homestead Act, 1862). Alternatively, an individual could pay $1.25 per acre and own the land immediately and outright (Homestead Act, 1862). This led to wealthy individuals amassing incredible swaths of land. Take The King Ranch for example: in south Texas, the now 825,000-acre ranch is the single largest contiguous private land parcel in the nation. (Kinnan,2014) To put in perspective the types of massive land holdings collected during this time, the aforementioned King Ranch is 37,000 acres larger than the state of Rhode Island (King Ranch, United States Forest Service, 1996). 

The second influential act of 1862 was the Pacific Railway Act signed into law on July 1st. President Lincoln designed the act to incentivize private railway companies to build a transcontinental railway. The act ensured that the railway companies were given ten one-square-mile plots of alternating public-private squares per mile of railway laid, extending perpendicularly away from the train tracks (Pacific Railway Act, 1862). The best way to imagine this type of land allocation pattern is to picture a checkerboard. The black squares are private parcels while the red ones are public. This type of land layout was chosen as a way to mitigate the railway companies owning large contiguous parcels of land along the length of the tracks.  These perfect mile-by-mile square parcels of land can still be observed today from the window of a plane.

The third and final major act influencing the layout of public and private land in the west was the Bankhead Jones Act of 1937. Signed into law by President Franklin D. Roosevelt, this act enabled the repurchasing of failed homestead land back from farmers and sharecroppers to be reabsorbed into the public land trust (Bankhead Jones Act, 1937). The result of the Bankhead Jones Act meant that random pieces of land were now a part of the public lands of America. In many cases those failed homesteads were completely surrounded by private land, meaning that no one except for the neighboring landowners had legal access to them. The combined impact of The Homestead Act (1862), The Pacific Railway Act (1862), and The Bankhead Jones Act (1937) has led to the layout of plots that we have in the American west today. 

Public Lands in the American West Today

OnX-Maps, a digital mapping company, and the Theodore Roosevelt Conservation Partnership (TRCP), a nonprofit spearheading conservation efforts across America, partnered in 2018 to survey public lands across 13 western states. This attempt to understand how many acres of public land are currently inaccessible to the public, produced alarming findings. The study revealed that 9.52 million acres of public land are “landlocked,” which is a larger quantity of land than New Hampshire and Connecticut combined (TRCP, 2018). The decided-upon definition of “landlocked” is “any isolated parcels of public land which are wholly enclosed or ‘landlocked’ by private landholdings through which no legal public road or trail passes” (TRCP, 2018). This means the only way to legally access these parcels of land is via small aircraft or in cases where a navigable waterway passes through the land. Water is a public resource, meaning that the landowner owns the river banks and bed but not the water itself; therefore, the public can float through private property without trespassing. Of the 13 states analyzed, Wyoming had the single most landlocked acres, at three million followed by Nevada and Montana with 2.05 and 1.52 million acres, respectively (TRCP, 2018). 

It is important to note that “landlocked” public lands have only recently become a cause of public outcry with the invention and implementation of modern mapping technology. Paper maps offer a level of ambiguity as to where property lines really lie as well as require a certain skill to be able to read. OnXMaps documents all of the parcels of land in the United States using satellite data providing accurate mapping information in a way that is easily read and interpreted. The increase in readability and accessibility of maps has shed a light on the problem of landlocked lands. No longer is the contemptible loophole of entrapping public lands within the bounds of private land in the shadows. 

Corner Crossing

There are several ways public lands can be trapped by private lands, the first of which is corner crossing. If we return to our checkerboard analogy, corner crossing is passing from one red square to another red square. That four-way intersection of two public parcels and two private parcels diagonally set from each other is where corner crossing occurs. This type of travel between two public parcels evolved  as a response to the perfect square parcels of the 1862 Pacific Railway Act. Currently as written by Wyoming law, corner crossing is not explicitly illegal or legal. The Wyoming Attorney General’s office maintains that corner crossing does not violate Wyoming Statute 23-5-305 (b) (trespass with the intention to hunt private land) but “may still be a criminal trespass under Wyoming Statute 6-3-303” (criminal trespass) (Crank, 2004). This means that Wyoming Game and Fish officers cannot charge individuals for corner crossing, leaving the sheriff's office or attorney's office to prosecute those individuals for possible infringement. Across the American west, corner crossing law is written in a similarly ambiguous manner: it is illegal in one context but not in another. While the general consensus suggests playing it safe and refraining from accessing public lands via corner crossing, that doesn't stop some individuals from trying their luck. 

Wyoming Hunters v. Elk Mountain Ranch

During the fall hunting season of 2021, four men from Missouri were hunting elk in the mountains of southern Wyoming about 65 miles northwest of Laramie. This part of the country is home to pristine landscapes and excellent elk hunting. The parcels of land in this area have been plotted in the same “checkerboarded” pattern as in many of the other western states. The four hunters had set up their camp on one parcel of public land and were hunting an adjoining public parcel. The two public parcels met at the corners of the squares (Lungren, 2021). The two other corners were private and are a part of the Elk Mountain Ranch, owned by Fred Eshleman; founder of Eshleman Ventures, an investment company specializing in the private healthcare sector (Thuermer Jr., 2022). 

The four hunters, familiar with the concept of corner crossing and the legal ambiguity revolving around the issue, had taken precautions to not set foot on any Elk Mountain Ranch property by placing a step ladder spanning from one public parcel to the other and therefore crossing over without touching the private land. The watchful ranch manager had observed this and called local law enforcement asking for the hunters to be charged with trespassing. Wyoming Game and Fish wardens came to the ranch and said there was nothing they could do and the actions of the hunters fell into a legally ambiguous gray area. Unsatisfied by the actions of the wardens, the ranch manager took matters into his own hands, following the hunters around on public land in his truck, getting into verbal confrontations, and impeding their pursuit of game. The ranch had also stationed several scouts to observe the hunters at their camp (Lungren, 2021).

The next day, the four hunters did the exact same thing as the day before, crossing the corner intersection of the plots via their homemade step ladder. Again, The ranch manager called the game and fish wardens and heard the same response. Another altercation occurred between the manager and the hunters. The next day the hunters followed the same route as days prior and were met by a law enforcement officer with direct orders to cite each man with criminal trespass, a $750 fine in the state of Wyoming. The reason for the citation was not because any individual had set foot on private land but because their bodies entered the airspace of the private land (Lungren, 2021). Property boundaries are infinitely small, meaning it is impossible not to enter the private land at those four-way corners. While the hunters never set foot on the land of the Elk Mountain Ranch, by the use of a step ladder they still entered the ranch's airspace. 

This case has gained national attention and through exposure from several media outlets across the country, the hunters entered court in April of 2022 backed by generous donations reaching over $60,000 from a GoFundMe spearheaded by Backcountry Hunters and Anglers and individual parties (Lungren, 2022). The Wyoming court unanimously found the hunters not guilty of criminal trespass and they were not forced to pay the $750 fine. The importance of this case cannot be understated; this ruling sets an important precedent in the state of Wyoming toward the legality of corner-crossing, and more importantly, Wyoming has set an example for other states with similar corner-crossing laws. 

However, the legal battle for these four men is not over. There is now a civil suit being raised against the hunters by Mr.Eshelman and the Elk Moutain Ranch. They are seeking $3.1 to $7.75 million dollars in damage restitution. The document put forth listing the damages has a $10.00 amount in physical damages. Where the actual damages that have supposedly been done is in the 10-25% diminution of the value of the $31 million dollar ranch appraised in 2017. In addition another $7500 in damages for interference with ranch operations including a military veterans hunting program. As of November 2022, this case is still open and awaiting trial (Thuermer Jr., 2022). 

The same GoFundMe as of November 2022 has raised over $114,000 to aid these men's legal fees. The overwhelming generosity of the public shows that this is an issue that matters and has support. People who hunt and recreate on public land have had to navigate alternatives to and being hindered by corner crossing for a very long time. This is an instance where we cannot let a bully win. The consequences if we do could mean millions of acres of public land would stay solely accessible to those who own and have permission to be on the adjoining private land. 

Durfee Hills

The second type of “landlocked” public lands are those that are entirely surrounded by private land. Picture a donut. The center hole is the public land while the surrounding pastry is the private land. The surrounding private land completely bars access to the public via ground. Located 100 miles north of Billings, Montana sits the famous Durfee Hills. The 2,785-acre parcel of Bureau of Land Management (BLM) land is home to a world-class elk herd and is an unparalleled example of a thriving western habitat (Geer, 2015), truly a hunter and wilderness lovers' paradise. There is only one problem. The public cannot access the land through reasonable means. The Durfee hills are the center of the donut, a landlocked parcel completely surrounded by private land. 

The surrounding land is owned by Texas oil brothers Dan and Farris Wilks, their 200,000-acre N-Bar Ranch is an impressive example of Montana history, housing in its borders the remnants of homesteads, Native American artifacts, and an American buffalo cliff jumping site (N-Bar Ranch, 2020). The ranch's previous owners as well as the Wilks brothers set out on a mission to buy all of the adjoining parcels of land to create the mega cattle ranch that it is today (N-Bar Ranch, 2020). This buying of neighboring plots led to the entrapment of the Durfee Hills by a sole entity. 

This intentional trapping of public land triggered massive public outrage. To give the metaphorical middle finger to the Wilks brothers, hunters, and outdoor recreators have started to charter helicopters and small aircraft to drop them into the Durfee Hills (Rinella, 2018). Currently, the only legal way to enter the BLM parcel is via aircraft. Around 80 hunters a year (Rinella, 2018) incur the exorbitant cost of chartering a private aircraft for drop-off and pick-up for the chance at pursuing a world-class elk population and to let their ill feelings towards the Wilks brothers to be heard and seen as they fly over. 

In an attempt to appease the public, the Wilks brothers offered a 5,100-acre parcel of land they owned in another section of the county in trade for the Durfee Hills (Geer, 2015). This sparked even further public outrage. The parcel offered by the brothers was desolate dry sagebrush country. While comparable in size to the Durfee Hills, the natural resource offerings were nowhere near the lush timber, healthy animal populations, and pristine habitat found in the Durfee Hills. Not surprisingly, Montana Fish and Game refused the trade (Geer, 2015). 

This display of intentional entrapment of public lands by the Wilks brothers and others across the West cannot be tolerated. While currently legal, this is a moral crime. By default, the Wilks brothers have sole access via ground. By surrounding the Durfee Hills, they have blocked access to a pristine example of what natural habitat in the American West should look like, taking America's land for themselves. Every American is an owner of public land, one of the great resources and benefits this country has to offer. However, with the exception of those 80 individuals a year who pay to fly into the Durfee Hills, no one is able to enjoy the land. The Wilks brothers have essentially made the Durfee hills a part of their ranch, a roughly 5,000-acre parcel they pay no taxes on and enjoy largely exclusive access to. 

Public Access Taken Too Far

Located 42 miles north of Grand Junction, Colorado sits The High Lonesome Ranch, a 225,000-acre working cattle ranch operated and owned by Paul R. Vahldiek, Jr., a former Texas trial lawyer (Bastone, 2018). Vahldiek, Jr. has dedicated his funds and decades of his life to conservation. He is passionate about creating a farming practice that benefits the land as much as the animals that inhabit it. The High Lonesome Ranch hosts world-renowned biologists, conservationists, and ecologists through his High Lonesome Ranch Institute program. The program sponsors and houses these scientists as well as their students to study the land, animals, and waters to better inform and improve Mr.Vahldiek’s conservation efforts (Conservation Visions, n.d). The High Lonesome Ranch is an exceptional model of private conservation. The standards set by the ranch owner and its managers far eclipse the standards set for management and conservation by the US Forestry Service, BLM, or the Fish and Game Agency (Conservation Visions, n.d).

In April 2016 commissioners representing Garfield County took legal action against the High Lonesome Ranch in a dispute over whether a set of service roads on the ranch were actually public, not private. The position of the county was that the High Lonesome was blocking another public vehicle access point through the gating of a historic public road. The 225,000-acre ranch borders a parcel of 50,000 acres of BLM land (On Land, 2021) and Mr.Vahldiek has been known to generously allow access through his land to the BLM land via foot or by horse but not by car (Bastone, 2018). A quick look at the Garfield County map of land parcels reveals the BLM parcel is accessible from a number of other public areas (Garfield County, n.d).  The county cited  RS 2477, a statute written in 1866, as the legal claim to its case. Statute 2477 is a single line of text that states, “The right-of-way for the construction of highways across public lands not otherwise reserved for public purposes is hereby granted” (RS 2477, 1866). The roads on the High Lonesome had been established as public corridors more than 100 years ago for wagons, horses, and foot travelers; however, the paths had not been used for decades long before the High Lonesome Ranch was established (On Land, 2021). During the court case, the judge ruled that the roads on the High Lonesome were in fact an extension of county road 200 and were public.  This required the ranch to remove its gates and offer unrestricted public access through seven miles of roads to the BLM parcel (Garfield County v. High Lonesome Ranch LLC, 2020). While the ranch appealed the ruling and the case is making its way up the circuit courts of Colorado and has the potential to go to the Supreme Court, this ruling could set a potentially dangerous precedent that threatens landowners all over the country. The discovery of any historic public path, no matter the size or significance, could be used to justify public vehicle thoroughfare through private land (On Land, 2021). 

This case is an example of exceptional foolishness. We as a public have now compromised the laborious efforts of a man who has dedicated his life to conservation and has established a continually evolving model that our federal government studies to improve conservation and land management practices all over the nation. The 50,000-acre parcel of BLM land had also reaped the benefits of Mr.Vahldiek’s conservation efforts, to which the public already had access. We are lucky to have an individual who is such a passionate steward of the Western landscape. The increased prevalence of motorized vehicles throughout his property and the further introduction of more motorized vehicles on the BLM plot will drastically impact the wildlife and plants, leaving scars upon the landscape in the form of tire tracks. We have surely set a dangerous precedent that has the potential to hinder our understanding and improvement of stewardship practices and destroy landscapes, and desolate wildlife. Some public places are necessarily harder to get to than others, and some require the use of feet, not a motor.

An International Look at Public Land Access

Many countries across Europe have taken a different approach to public land access. In the UK, Scandinavia, and Estonia there is a law called the “Right to Roam'' or the “Roamers Law” (Sotolongo, 2018), and it is rather easy to understand. An individual has the right to go wherever they wish. Of course, there are some exceptions. Travelers and recreationists cannot go on plots actively growing crops or within a certain distance of private homes and buildings or private gardens. This means that individuals have the right to recreate and pass through private land as they see fit ( UK Roamers Right, 2000), (Swedish Right To Public Access, n.d). This right comes with an expectation of behavior that the land is respected and individuals operate by the “leave no trace” principles so others may enjoy the land the same as they did (Sotolongo, 2018). In a brilliant marketing campaign by the Swedish Tourism Board, the entire country of Sweden was listed on Airbnb for free (Visit Sweden, 2021), demonstrating perfectly the idea of the freedom to roam. 

Finding a Solution

A fundamental belief of America is that individuals have the right to own property and largely govern the activities and happenings of that purchased land. I agree wholeheartedly. In fact, my life's dream is to own a large bison ranch. The right to property does not only include private lands but public as well. Public lands are owned by the people. An extraordinary resource and benefit of living in America are the over 640 million acres of public land that anyone has the right to access (Congressional Research Service, 2020). However, there are some who have blocked access to sections of America's land. The individuals who have entrapped pieces of public land within the bounds of their private estates have effectively stolen 9.52 million acres of land from American citizens. Denying individuals access to their land is wrong. 

To combat these predatory individuals as well as release parcels of public land that through circumstance has become confined within the boundaries of private plots; there needs to be easements put in place allowing access through the private land to the public land. Easements are “a right to cross or otherwise use someone else's land for a specified purpose,” in this case, the establishment of a specific route that cannot be varied upon by users under threat of trespass. These routes should be determined by the landowner in conjunction with representatives from the US government. In addition, the type of access shall be determined solely by the landowner with a base level of access via foot. To protect the landowner a waiver must be signed or an understanding of risk established so the person using the easement cannot press legal action against the landowner in the event of injury. As written in the 5th Amendment of the United States Constitution “nor shall private property be taken for public use, without just compensation” (United States Constitution, 1787). The easements would mean at a minimum the sacrifice of a walking trail width of land by the landowners and would entail fair payment on the part of our federal or state governments.

Addressing the comparatively straightforward issue of corner crossing, an easement could be a possible solution; however, a less complicated solution could be used. A change in legislation could simply allow the crossing from one public parcel to another without setting foot on private land at the four-way corner intersection of alternating private and public lands. In the case where fencing has been placed at those corners, the utilization of a fence ladder shall be permanently installed and maintained by government employees. Inevitably in either of these cases while no individuals or objects are touching the land they are still interacting with the airspace above the private land and fair compensation shall be granted there as well, as established by the 1946 United States Supreme Court Case United States V. Causby (United States V. Causby, 1946).

 In the interim, a program where sympathetic landowners could enroll their properties to allow corner crossing and unfettered passage to public lands in exchange for some form of compensation would be a great first step to unlocking our public lands while not being yet mandated.  

Conclusion

Finding solutions to unlocking America's public lands means additional access to an area totaling more than the combined acreage of New Hampshire and Connecticut. These solutions would mean allowing access through private lands in trade for just compensation to the landowner. Some parcels are trapped by happenstance, while others have been purposefully surrounded by landowners looking to bar public access and reserve exclusive usage of the land. We have over 640 million acres of public land in the United States (Congressional Research Service, 2020) and each and every one of those acres should be accessible within reason for the enjoyment of those who are willing to travel there. The harboring of public lands within the confines of private property is akin to stealing that land. This theft on a massive scale impacts everyone and has gone on too long and has not been brought to the public’s attention. It’s time for our public lands to once again become accessible to the everyman. 

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