In 1937, Congress passed the Oregon and California Railroad and Coos Bay Wagon Road Grant Lands Act of 1937 (O&C Act), which set aside nearly 2.6 million acres of Oregon forestland as a permanent trust for local governments to fund public services. Congress mandated that these timberlands "shall" be managed for "permanent forest production" and that timber thereon be cut and sold under "the princip[le] of sustained yield" to generate revenue for the affected counties. 43 U.S.C. §§ 2601, 2605. Despite this clear congressional mandate, the President used the Antiquities Act of 1906 to add tens of thousands of O&C timberland acres into a national monument where sustained-yield timber harvest is prohibited. Similarly, the Bureau of Land Management (BLM) issued management plans for the entirety of the O&C forestlands that dedicated 80% of the O&C lands to noharvest "reserves" for conservation purposes.

The questions presented are:

Whether the President can use an Antiquities Act Proclamation to override Congress's plain text in the O&C Act to repurpose vast swaths of O&C timberlands as a national monument where sustained-yield timber production is prohibited.

Whether the Secretary of the Interior can override the O&C Act by designating 80% of the O&C timberlands as conservation "reserves" where sustained-yield timber harvest is prohibited.

Whether the President can use an Antiquities-Act-Proclamation to override Congress's plain-text-in-the-O&C-Act to repurpose vast-swaths-of-O&C-timberlands-as-a-national-monument-where-sustained-yield-timber-production-is-prohibited