Russell Black v. Bureau of Parks and Lands

Summary

The court held that the appeal remained justiciable because retroactive application of the citizens’ initiative to the leases would substantially impair contractual obligations in violation of the federal Contract Clause. It further held that the Bureau was not required to use a formal administrative process before granting the leases, but was required to determine whether a proposed lease would substantially alter public reserved lands. Applying the pre-initiative law and the undisputed record, the court concluded that the lease did not substantially alter the lands, vacated the trial court’s judgment, and remanded for judgment in favor of the Bureau and CMP.