Wampler v. Lecompte

Background

Maryland’s game laws authorize annual licenses to build and maintain duck blinds in state waters, with rules on how far blinds can be from shore and how far apart they must be. Riparian (waterfront) owners get first choice of blind locations, but may not place a blind within 250 yards of a neighbor’s dividing line without that neighbor’s consent. Some waters have different rules, including outright bans or unconditional renewals. A waterfront owner with less than 44 feet of frontage built a blind within 250 yards of adjacent owners; game wardens destroyed it and threatened further enforcement. He sued, arguing the law unfairly favored owners with large frontages and treated different waters unequally under the Fourteenth Amendment’s equality requirement. Lower courts dismissed his claim and affirmed the law’s validity.

Reasoning

The Court addressed whether the statute’s classifications were unreasonable or violated equality. It accepted the state court’s findings that the rules aim to conserve waterfowl and protect people who hunt them, and that spacing, distance-from-shore, and consent rules are related to those goals. The Court found no showing that the legislature acted unreasonably. The consent rule is a necessary part of giving riparian owners priority, and small-frontage owners can combine efforts with neighbors to meet spacing rules. Special rules for certain waters were presumed justified by local facts the legislature could consider.

Real world impact

The decision lets Maryland enforce its detailed blind-placement and spacing rules and defenses against blinds built too close to neighbors. Waterfront owners with small frontages may need neighbor consent or cooperation to place blinds. The ruling affirms the state’s authority to tailor hunting regulations for conservation and safety.