Collins v. Yosemite Park & Curry Co.

Background

A private company that runs hotels, camps, and stores under a contract with the Secretary of the Interior in Yosemite National Park sued California state officials. The State Board of Equalization and the Attorney General said the state Alcoholic Beverage Control Act applied inside the Park, requiring licenses, reporting, and subjecting sales to penalties and fees. The company said the federal government has exclusive jurisdiction in the Park and asked a court to stop the State from enforcing the law there. The District Court agreed and issued an injunction barring enforcement of the state law in the Park.

Reasoning

The Supreme Court examined whether the United States has exclusive jurisdiction in Yosemite and what rights California kept by statute. The Court held that the United States has exclusive jurisdiction over the Park except for specific reservations the State kept, including the right to tax persons and property. The Court ruled that California cannot enforce the Act’s licensing and other regulatory provisions within the Park, because those go beyond the reserved right. But the Court found the excise-tax provisions of the state law fall within the reservation and may be enforced as revenue measures.

Real world impact

The decision means businesses operating under federal leases in Yosemite cannot be forced to obtain the state liquor licenses or submit to state regulatory conditions, but they remain subject to state excise taxes on alcoholic beverages sold in the Park. The Court reversed the District Court’s broad injunction and sent the case back for the lower court to sort out which specific sections of the Act apply.

Dissents or concurrances

Justice McReynolds agreed the decree should be reversed on the tax-reservation point and thought discussion should be confined to that issue.