It is unlikely that Ammon Bundy and friends, currently illegally occupying the Malheur National Wildlife Refuge in Oregon, planned their protest against federal land management policies in the West to coincide with the upcoming Supreme Court argument in Sturgeon v. Frost, but the standoff in Oregon and the issues in this case spring from the same well.

The big-picture issue in both cases is the extent of federal power over lands in the West. To those of us living east of the 100^th Meridian, which runs roughly down the eastern border of Colorado in Figure 1, the issue is not significant, but to those who live west of that line, it is of paramount concern. The federal government owns less than two percent of land in my home state of Illinois, but nearly eighty-five percent of Nevada and, for purposes of this case, about sixty-nine percent of Alaska (amounting to over several hundred million acres). These numbers matter to perceptions. For the typical Easterner, the idea of federal power to conserve lands is likely unobjectionable and agency power (whether it is the National Park Service or Bureau of Land Management) is likely perceived as benign and socially regarding. But for the typical Westerner, who has to live with federal land management policies on a daily basis, the warts and shortcomings of federal policies often implicate economic survival.

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