Conclusion

The hypothetical Denali Wolf Protection Act illustrates the Property Clause’s extraterritorial reach. While the extent of the extraterritorial reach remains debatable, the Alford-Camfield Nexus Rule provides an ascertainable standard for courts to apply. The rule provides that an extraterritorial regulation, to be constitutional, must be reasonably necessary, thus satisfying the “needful” requirement of the Property Clause, while the regulated activity on nonfederal land must have a substantial relationship to federal land, thus satisfying the “respecting” requirement of the Property Clause.  

Although Block and the Wild Horses Act suggest that the extraterritorial reach of the Property Clause may be without limits, the Alford-Camfield Nexus Rule informs that this extraordinary power does have limits. As traditional arbiters of conflicts between competing land uses, courts are well equipped to apply the limits reasonably and justly.