State Ex Rel. Cox v. Hibbard

570 P.2d 1190, 31 Or. App. 269, 8 Envtl. L. Rep. (Envtl. Law Inst.) 20127, 1977 Ore. App. LEXIS 1969
CourtCourt of Appeals of Oregon
DecidedOctober 24, 1977
Docket75-356-E-2, CA 7125
StatusPublished
Cited by4 cases

This text of 570 P.2d 1190 (State Ex Rel. Cox v. Hibbard) is published on Counsel Stack Legal Research, covering Court of Appeals of Oregon primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
State Ex Rel. Cox v. Hibbard, 570 P.2d 1190, 31 Or. App. 269, 8 Envtl. L. Rep. (Envtl. Law Inst.) 20127, 1977 Ore. App. LEXIS 1969 (Or. Ct. App. 1977).

Opinion

*[271] THORNTON, J.

Defendants appeal from a decree enjoining them from removing in excess of 50 cubic yards of material in any calendar year from Forest Creek in Jackson County, Oregon, without obtaining a permit from the Director of the Division of State Lands pursuant to ORS 541.615 (l). 1

Plaintiffs complaint for mandatory injunction alleged that defendants "removed the top layer of soil in and near Forest Creek by causing a trench to be dug approximately 200 feet long and from 6 to 10 feet wide, which soil was left to form a vertical unstable bank” and sought a decree requiring defendants to restore Forest Creek to its original condition and "[f]or such other relief as may deem to the Court to be reasonable and proper.”

Defendants advance nine assignments of error. The first three assignments all arise out of a trial court order sustaining a demurrer to defendants’ second affirmative defense. Defendants’ second affirmative defense is a federal preemption claim in which it is alleged that "defendants have been and now are the owners of the Gold Dust placer unpatented mining claims Nos. 1 through 8, in Section 31, Township 17 South, Range 3 West, W.M., in the Upper Applegate Mining District, Jackson County, Oregon, subject only to the paramount title of the United States. Said ground was duly and regularly located on public domain land of the United States.” Defendants then invoke the Property Clause of the United States Constitution, Art IV, §3, clause 2, 2 the Supremacy *[272] Clause of the United States Constitution, Art VI, clause 2, * 3 federal mining laws, 30 USC § 21 et seq, and an "Acceptánce by Oregon of Propositions Offered by Congress in Admission Act” approved by the Oregon Legislative Assembly June 3, 1859, and assert the imconstitutionality of ORS 541.605 to 541.695 as applied to federal lands.

By way of background we should state that there are four general kinds of federal jurisdiction over federal lands: exclusive legislative jurisdiction, concurrent legislative jurisdiction, partial legislative jurisdiction and proprietorial legislative jurisdiction. See, Report of the Interdepartmental Committee for the Study of Jurisdiction over Federal Areas within the States, Part I, at 15-22 (1956); Public Land Law Review Commission, Federal Legislative Jurisdiction, Study Report No. 1 at 56-58 (1969); Landstrom, State and Local Regulation of Private Land Using Activities on Federal Lands, 7 Natural Resources Lawyer 77 (1974).

Exclusive, concurrent and partial legislative jurisdiction are dependent on the Jurisdiction Clause, Art I, § 8, clause 17, United States Constitution, 4 and *[273] specific agreements between the state and federal governments with respect to a particular parcel of land. Since the defendants in this case have not asserted a Jurisdiction Clause claim, have not asserted that the Admission Act of 1859 applies to the land on which they mine their claim 5 and have not indicated in this record the nature or extent of the United States’ interest in the land, we assume that interest is proprietorial.

The Supreme Court of Idaho has recently rejected a claim similar to that advanced here, finding no express or implied federal preemption. The defendants in State ex rel Andrus v. Click, 97 Idaho 791, 554 P2d 969 (1976), like the defendants in this case, asserted that federal preemption of state environmental regulation on federal land based on the Property Clause, the Supremacy Clause and federal mining laws, 30 USC § 21 et seq, prohibited the state from requiring defendants to obtain a permit prior to mining their claim. In rejecting defendants’ preemption claim, the Idaho Supreme Court noted:

" * * * [W]e find nothing in the federal statute or its legislative history to indicate an intent to preempt state regulation. Indeed, the federal statute specifically recognizes the state’s right to impose additional requirements *[274] in some areas. For example, even where standards are set for the location of mining claims, nonconflicting state requirements are upheld. 30 U.S.C. § 26; I.C. § 47-601 et seq.
"Nor can the federal statute be characterized as a pervasive regulatory scheme. If anything, the federal statute is characterized by its absence of regulation. Although the Forest Service recently promulgated regulations which purport to give them a greater part in the control of mining operations, 39 Fed. Reg. 31317-21, both these regulations and the statutes authorizing their promulgation specifically recognize the viability of existing state regulations. 16 U.S.C. §§ 551, 551a.
"We also fail to find preemptive qualities in the nature of the subject matter regulated. As stated in Mendiola v. Graham, 139 Or. 592, 10 P.2d 911, 915 (1932):
" 'It will not be contended that the federal government has not the right to conserve the natural resources of the public domain, and, where the federal government has not acted, the state, through its police power, may exercise such right and privilege. The state, as well as the United States, is vitally interested in preserving the natural resources within its boundaries.’
Indeed, the preservation of the environmental quality of its lands is a subject particularly suited to administration by the states. Congress has recognized that even where extensive federal environmental legislation exists, the primary responsibility for implementing environmental policy rests with state and local governments. 42 U.S.C. § 4371(b) (2); see also 42 U.S.C. § 4331(a).” 97 Idaho at 798.

We likewise conclude that federal mining laws do not indicate an intent to preempt state regulation and we find no conflict between any particular provision of the federal mining laws and ORS 541.605 to 541.695. See, Kleppe v. New Mexico, 426 US 529, 96 S Ct 2285, 49 L Ed 2d 34 (1976); Omaechevarria v. Idaho, 246 US 343, 38 S Ct 323, 62 L Ed 763 (1918); Shapiro, Energy Development on the Public Domain: Federal/State Cooperation and Conflict Regarding Environmental

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Bluebook (online)
570 P.2d 1190, 31 Or. App. 269, 8 Envtl. L. Rep. (Envtl. Law Inst.) 20127, 1977 Ore. App. LEXIS 1969, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-ex-rel-cox-v-hibbard-orctapp-1977.