On October 20, 2025, the Supreme Court of the United States (“SCOTUS”) denied review of the “corner crossing case” legally known as Iron Bar Holdings v. Cape, et al.. As discussed in previously in these pages the case arose in the Federal District Court for the District of Wyoming between a large ranch owner, Iron Bar Holdings, and five hunters. After Iron Bar was unsuccessful in pursuing criminal charges against the hunters in Wyoming state court, the ranch sought damages under multiple theories, including civil trespass, in federal court.
Background
The activities given rise to the case included the hunters’ use of land-locked public land owned by the Bureau of Land Management to hunt elk. The hunters pursued elk across checkerboarded public land, crossing where the corners of the federal land met, i.e. “corner crossing.” The other landowner on the checkerboard, Iron Bar, posted and fenced off its private parcels, effectively blocking access to public land via connected corners. The hunters circumvented Iron Bar’s efforts by using an a-frame ladder with bases placed on adjoining public land to climb over Iron Bar’s infrastructure without making physical contact with Iron Bar’s private land.
Iron Bar sued for trespass of the “air space” over its private land, claiming such access to the land-locked public land diminished the value of its private property to the tune of millions of dollars. Of note, Iron Bar’s operations include guided private hunts that access the elk-rich public land adjoining its private property. Iron Bar historically attempted to bar other hunters from using the public land, including the hunters subject to the law suit.
Court Decisions
The Wyoming Federal District Court ruled in favor of the hunters. The Court found the federal Unlawful Inclosures Act prohibited Iron Bar from limiting access and use of public land, finding its efforts constituted an enclosure of public land. The District Court further found the hunters’ access through Iron Bar’s air space was not a trespass absent damage to Iron Bar’s physical property.
The Tenth Circuit Court of appeal upheld the District court order. (More on its holding here). Iron Bar subsequently appealed the case to SCOTUS on July 16, 2025. Iron Bar’s position was supported by multiple amicus briefs requesting SCOTUS review in order to overturn the Tenth Circuit Opinion—these included Wyoming Stock Growers Association, Wyoming Wool Growers Associated, and Montana Stock Growers Association. While the hunters opposed the Supreme Court review, interest groups that supported the hunters were likewise interested in SCOTUS review to issue a ruling on corner-crossing that would clarify this legally “grey” area across all public land in the U.S.
Implications of Denying the Corner Crossing Review
Regardless of the amici and public interest, SCOTUS denied the corner crossing review. As such, the Tenth Circuit Court of Appeals opinion on corner crossing of public lands stands. Notably, public land access is a concern in other appellate jurisdictions, including the Ninth Circuit.[1] Absent a SCOTUS ruling, the corner crossing litigation is not binding on those jurisdictions outside of the 10th Circuit. However, it will likely be the basis of strong persuasive precedence on how corner crossing should be addressed throughout the West.
[1] The Ninth Circuit encompasses, but is not limited to Alaska, Arizona, California, Idaho, Montana, Nevada, Oregon, and Washington.
