Amicus Curiae Brief — Alaska, et al., Petitioners v. United States, et al.

No. 25-320

IN THE

Supreme Court of the United States

__________________________________________________

STATE OF ALASKA, ET AL.,

Petitioners,

v.

UNITED STATES OF AMERICA, ET AL.,

Respondents.

__________________________________________________

On Petition for a Writ of Certiorari to the United

States Court of Appeals for the Ninth Circuit

__________________________________________________

BRIEF OF STATE OF IDAHO, 19

OTHER STATES, AND THE ARIZONA

LEGISLATURE AS AMICI CURIAE IN

SUPPORT OF PETITIONERS

__________________________________________________

R. TRENT MCCOTTER

WALKER FORTENBERRY*

BOYDEN GRAY PLLC

800 Connecticut Ave. NW

Suite 900

Washington, DC 20006

(202) 706-5488

tmccotter@boydengray.com

*Admitted only in

Alabama; practice

supervised by D.C. Bar

Members

October 17, 2025

RAÚL R. LABRADOR

Attorney General

ALAN HURST

Solicitor General

Counsel of Record

MICHAEL A. ZARIAN

Deputy Solicitor General

SCOTT L. CAMPBELL

ROBERT M. FOLLETT

W. DALLAS BURKHALTER

MARSHALL W. TORYANSKI

Deputy Attorneys General

OFFICE OF THE IDAHO

ATTORNEY GENERAL

700 W. Jefferson St.

Ste. 210

Boise, ID 83720

alan.hurst@ag.idaho.gov

(208) 334-2400

[Additional Counsel Listed with Signature Block]

i

TABLE OF CONTENTS

TABLE OF AUTHORITIES ....................................... ii

INTEREST OF AMICI CURIAE ............................... 1

SUMMARY OF THE ARGUMENT ........................... 3

ARGUMENT .............................................................. 4

I.

The Decision Below Is Irreconcilable with

Sturgeon and Portends a Massive Shift in

Power Away from States. .................................... 4

II. The Ninth Circuit Failed to Apply the ClearStatement Doctrine, Which Protects State

Sovereignty. ......................................................... 9

III. Even if the United States Could Hold Title to

an Implied Water Right, the Ninth Circuit’s

Decision Was Still Wrong. ................................. 12

CONCLUSION ......................................................... 14

ii

TABLE OF AUTHORITIES

Page(s)

Cases

Ala. Ass’n of Realtors v. HHS,

594 U.S. 758 (2021) ................................................ 6

California v. United States,

438 U.S. 645 (1978) .............................................. 10

Idaho v. Coeur d’Alene Tribe of Idaho,

521 U.S. 261 (1997) ................................................ 8

Sackett v. EPA,

598 U.S. 651 (2023) ................................................ 9

Solid Waste Agency of N. Cook Cnty. v.

U.S. Army Corps of Eng’rs,

531 U.S. 159 (2001) ......................................... 9, 10

Sturgeon v. Frost,

577 U.S. 424 (2016) ................................................ 4

Sturgeon v. Frost,

587 U.S. 28 (2019) .................................... 3, 5, 7, 12

Tenn. Valley Auth. v. Hill,

437 U.S. 153 (1978) ................................................ 6

United States v. Bass,

404 U.S. 336 (1971) ................................................ 9

United States v. New Mexico,

438 U.S. 696 (1978) ...................................... 1, 3, 12

United States v. Oregon,

295 U.S. 1 (1935) .................................................... 9

Utah Div. of State Lands v. United States,

482 U.S. 193 (1987) .............................................. 10

iii

Will v. Mich. Dep’t of State Police,

491 U.S. 58 (1989) .................................................. 9

Statutes

16 U.S.C. § 3102 ............................................ 4, 5, 7, 12

16 U.S.C. § 6502 .......................................................... 8

16 U.S.C. § 7911 .......................................................... 8

43 U.S.C § 1702 ........................................................... 8

26 Stat. 215, 215 Ch. 656 (1890) ............................... 10

Other Authorities

Carol Hardy Vincent & Laura A.

Hanson, Cong. Rsch. Serv., R42346,

Federal Land Ownership: Overview

and Data (updated 2020), available

at https://tinyurl.com/yck9xejr .......................... 1, 8

1

INTEREST OF AMICI CURIAE1

The States of Idaho, Alabama, Arkansas, Florida,

Indiana, Iowa, Louisiana, Mississippi, Missouri,

Montana, Nebraska, North Dakota, Ohio, Oklahoma,

South Carolina, South Dakota, Tennessee, Texas,

Utah, West Virginia, and the Arizona Legislature

(“Amici States”) support granting Alaska’s petition for

a writ of certiorari and reversing the Ninth Circuit’s

decision holding that “public lands” under Title VIII

of the Alaska National Interest Lands Conservation

Act (“ANILCA”) includes federal water-reservation

rights. In so holding, the Ninth Circuit divested a

state of its traditional authority over its navigable

waters based on an untenable expansion of the

implied-reservation-of-water doctrine.

In the West, water is scarce, but federal land is not.

Alaska itself is 61% federal lands, and Idaho is 62%.2

Federal lands average approximately 46% of land

within the eleven coterminous western states.3 “More

than 60% of the average annual water yield in the

[eleven] Western States is from federal reservations.”

United States v. New Mexico, 438 U.S. 696, 699 n.3

(1978).

1

No counsel for any party has authored this brief in whole or in

part, and no entity or person, aside from amici’s counsel, made

any monetary contribution intended to fund the preparation or

submission of this brief. All parties have received timely

notification of the filing of this brief.

2

Carol Hardy Vincent & Laura A. Hanson, Cong. Rsch. Serv.,

R42346, Federal Land Ownership: Overview and Data 7 (updated 2020), available at https://tinyurl.com/yck9xejr.

3

Id. at 19.

2

Although at first blush the Ninth Circuit appears

to have addressed a limited question about Alaska

and ANILCA, in reality the court blessed an

application of the federal reserved-water-rights

doctrine that threatens the longstanding deference to

state law for governing water throughout the West.

In reaching that outcome, the Ninth Circuit not

only contradicted this Court’s 2019 decision in

Sturgeon v. Frost, but also failed to heed the “clearstatement” rule that protects state sovereignty from

questionable attempts to shift the balance of power

towards the federal government over areas of

traditional state regulation, including water

management within a state’s borders.

Amici States maintain a strong interest in narrow

application of federal preemption, particularly in the

water-law context. To this end, Amici States are

interested in assuring that federal reserved water

rights are properly interpreted and adjudicated.

Given the profound errors in and detrimental

consequences flowing from the decision below, this

Court should grant review and reverse.

3

SUMMARY OF THE ARGUMENT

The decision below rests on several profound

errors worthy of review and correction by this Court.

First, the Ninth Circuit’s opinion squarely conflicts

with this Court’s decision in Sturgeon v. Frost, 587

U.S. 28 (2019), which held that Alaska’s navigable

waters are not “public lands” under ANILCA. See

Part I, infra. To be sure, Sturgeon addressed ANILCA

Title I, whereas this case involved ANILCA Title VIII,

but Congress expressly dictated that the same

definition applies to both Titles. The Ninth Circuit,

however, claimed the meaning of “public lands” differs

dramatically between Titles I and VIII, relying on an

unpersuasive theory that Congress had ratified the

Ninth Circuit’s pre-Sturgeon approach—despite there

being no intervening change to the definition of

“public lands.”

Second, even if there were some ambiguity in

“public lands” in Title VIII (and, after Sturgeon, there

is not), it would be resolved in Alaska’s favor under

the clear-statement doctrine, which requires courts to

presume that Congress did not intend to supersede

state authority in areas traditionally regulated by

states—like water management—unless such intent

is clearly manifested in the relevant statute. See

Part II, infra. But the Ninth Circuit oddly held that

this long-standing rule did not apply here because it

did not qualify as new, intervening authority.

Third, even if the United States could hold title in

a reserved interest in water, it would be limited to the

“amount of water necessary to fulfill the purpose of

the reservation, no more.” New Mexico, 438 U.S. at

700. An actual adjudication must determine the

4

existence and scope of federal reserved water rights,

rather than back-door federal regulations. But the

Ninth Circuit never even addressed this requirement.

See Part III, infra.

Although the discrete issue before the Court is the

interpretation of “public lands” under Title VIII of

ANILCA, whether a state-owned navigable river

qualifies as “public land” touches “on vital issues of

state sovereignty.” Sturgeon v. Frost, 577 U.S. 424,

441 (2016). Under the equal footing doctrine, each

state enters the Union with the same rights as the

other states. As part of equal footing, each state

retains its sovereign control of navigable waters

within its borders. The Ninth Circuit’s decision below

threatens to deprive western states of their

constitutionally guaranteed control of navigable

waters.

Moreover, the Ninth Circuit’s interpretation is farreaching, as the term “public lands” appears hundreds

of times across similar provisions in Title 16. In these

provisions, “public lands” is often defined using

language like ANILCA’s definition. The decision risks

throwing into chaos the entire realm of water law in

the West.

The Court should grant Alaska’s petition for a writ

of certiorari.

ARGUMENT

I.

The Decision Below Is Irreconcilable with

Sturgeon and Portends a Massive Shift in

Power Away from States.

For something to qualify as “public lands” under

ANILCA, the United States must have “title” in it,

among other requirements. 16 U.S.C. § 3102(1)–(3). In

5

Sturgeon, this Court addressed whether the United

States has “title” to an “interest” in the Nation River

in Alaska. 587 U.S. at 43. The Court held that there

was “no evidence that the Congress enacting

ANILCA” intended to allow the United States “to hold

‘title’ … to reserved water rights.” Id. at 43–44. Such

rights are “usufructuary,” meaning available “for the

Government to use” but “not own.” Id. at 43.

In other words, “reserved water rights are not the

type of property interests to which title can be held.”

Id. at 44. Because of that, “public lands” in Title I of

ANILCA cannot include reserved water rights, as the

United States cannot possess title in them. See 16

U.S.C. § 3102(1)–(3).

To be sure, Sturgeon addressed “public lands” as it

appeared in Title I of ANILCA, see 587 U.S. at 45 n.2,

while this case is about “public lands” as it appears in

Title VIII of ANILCA. But Congress has expressly

dictated that the same definition must apply for all of

ANILCA (i.e., “[a]s used in this Act”), except “titles IX

and XIV.” 16 U.S.C. § 3102.

This yields a simple syllogism: this Court has

interpreted “public lands” as categorically excluding

reserved-water rights, and by statute that same

definition must apply to Title VIII of ANILCA, too.

Accordingly, “public lands” in Title VIII cannot

include reserved-water rights.

That obvious outcome should have resolved this

case in Alaska’s favor. Nevertheless, the Ninth Circuit

persisted in its pre-Sturgeon view that the term

“public lands” in Title VIII includes reserved-water

rights. The court offered several reasons, but

respectfully, none is remotely persuasive.

6

The court claimed its prior interpretation of

“public lands” in Title VIII had been ratified by

Congress in the 1990s via “appropriations acts.”

Pet.App.4a; id. at 33a–38a. That is a non-starter

because Congress did not touch the definition of

“public lands.” This Court has cautioned against

relying on appropriations acts to conclude that

Congress modified existing statutory text or ratified

some then-extant judicial or executive interpretation

of a statute. See Tenn. Valley Auth. v. Hill, 437 U.S.

153, 190 (1978) (“The doctrine disfavoring repeals by

implication applies with full vigor when the

subsequent legislation is an appropriations

measure.”) (cleaned up).

For example, the CDC’s sweeping eviction

moratorium during COVID-19 was originally slated to

expire on December 31, 2020, but “Congress extended

it for one month as part of the second COVID-19 relief

Act”—an appropriations act. Ala. Ass’n of Realtors v.

HHS, 594 U.S. 758, 760 (2021). The government

contended this showed congressional ratification of

the CDC’s authority to issue such a moratorium, but

this Court rejected that argument, holding that

Congress had not “specifically authorized the action

that the CDC has taken” and that the challengers

were “virtually certain to succeed on the merits of

their argument that the CDC has exceeded its

authority.” Id. at 759–60.

The same logic applies here: appropriations acts

did not change the meaning of “public lands” in

ANILCA. But even if they did, Sturgeon post-dates

that supposed ratification and thus inherently

rejected it. The Ninth Circuit was required to follow

7

the 2019 Sturgeon decision, not tea leaves from 1990s

appropriations acts.

The Ninth Circuit also claimed that statutory

“context and objective[s]” could overcome Sturgeon

and § 3102, Pet.App.32a, but Sturgeon itself rejected

the argument that “statements of purpose” could

somehow “override [the] statute’s operative

language,” 587 U.S. at 57 (cleaned up). Also, to be

clear, the Ninth Circuit’s interpretation of “public

lands” in Title VIII is not just “different” or “distinct”

from this Court’s interpretation in Sturgeon,

Pet.App.25a–26a, but rather is directly contrary to it.

This was not some slight interpretive nuance based on

context—it was a polar-opposite interpretation.

Ironically, the Ninth Circuit’s view that “public

lands” in Title VIII of ANILCA means something

different than “public lands” in Title I is contrary to

the Ninth Circuit’s own prior holding that “[i]t would

be anomalous” to “employ[] a different construction of

‘public lands’ than applicable elsewhere in ANILCA.”

Sturgeon, 872 F.3d 927, 934 (9th Cir. 2017). If the

Ninth Circuit had followed that holding here, it would

have held that Sturgeon dictated the meaning of

“public lands” in Title VIII, too. However, the Ninth

Circuit’s concern about differing definitions for the

same term has apparently gone by the wayside.

Thus, far from “harmoniz[ing]” precedent,

Pet.App.4a, the decision below made a hash of it. The

Ninth Circuit chose to follow circuit precedent that is

inconsistent with this Court’s opinion in Sturgeon,

while discarding circuit precedent that would have

yielded the outcome demanded by Sturgeon.

8

The effects of the decision below will extend far

beyond Alaska. “Navigable waters uniquely implicate

sovereign interests.” Idaho v. Coeur d’Alene Tribe of

Idaho, 521 U.S. 261, 284 (1997). By insisting that the

200-plus uses of “public lands” in ANILCA might each

have its own bespoke definition, perhaps directly

contrary to the definition Sturgeon announced, the

Ninth Circuit risks throwing the rules for state water

management into chaos. And that is before accounting

for the fact that numerous other statutes also use the

term “public lands” and thus likewise—under the

opinion below—could allow the federal government to

usurp states’ water rights without statutory support.

Pet.24 & n.3.

For example, the Federal Land Policy and

Management Act (“FLPMA”), defines “public lands” as

“any land and interest in land owned by the United

States within the several States and administered by

the Secretary of the Interior through the Bureau of

Land Management.” 43 U.S.C § 1702(e) (emphasis

added). Throughout Title 16, this definition is

incorporated into dozens of other statutes. See, e.g., 16

U.S.C. §§ 6502(1)(B), 7911(1)(B). Because ownership

is an even broader concept than title, the Ninth

Circuit’s broad interpretation of “title” threatens to

open the door to expansive readings of these other

statutes.

In Idaho, the Bureau of Land Management already

manages over 11 million acres of land.4 The specter of

courts misinterpreting and expanding the scope of

“public lands”—not just in ANILCA, but also other

statutes like FLPMA—is an alarming threat to Idaho

4

Vincent & Hanson, supra note 2, at 9.

9

and other states’ control over their land and navigable

waters.

II.

The Ninth Circuit Failed to Apply the

Clear-Statement Doctrine, Which Protects

State Sovereignty.

Even if there were lingering uncertainty about

whether Sturgeon directly resolved the meaning of

“public lands” in Title VIII of ANILCA, the clearstatement doctrine should have removed all doubt and

dictated a ruling in Alaska’s favor. But the Ninth

Circuit oddly held this long-standing doctrine was

inapplicable because it did not qualify as new,

intervening precedent. Pet.App.39a. That was error.

“Congress should make its intention ‘clear and

manifest’ if it intends to pre-empt the historic powers

of the States.” Will v. Mich. Dep’t of State Police, 491

U.S. 58, 65 (1989). “In traditionally sensitive areas,

such as legislation affecting the federal balance, the

requirement of clear statement assures that the

legislature has in fact faced, and intended to bring

into issue, the critical matters involved in the judicial

decision.” Id.; see also Sackett v. EPA, 598 U.S. 651,

679 (2023); Solid Waste Agency of N. Cook Cnty.

(“SWANCC”) v. U.S. Army Corps of Eng’rs, 531 U.S.

159, 172–74 (2001); United States v. Bass, 404 U.S.

336, 349 (1971).

Management over a state’s own water is forefront

among such historic powers. “Dominion over

navigable waters and property in the soil under them

are so identified with the sovereign power of

government that a presumption against their

separation from sovereignty must be indulged.”

United States v. Oregon, 295 U.S. 1, 14 (1935). “The

10

history of the relationship between the Federal

Government and the States in the reclamation of the

arid lands of the Western States is both long and

involved, but through it runs the consistent thread of

purposeful and continued deference to state water law

by Congress.” California v. United States, 438 U.S.

645, 653 (1978).

Indeed, state ownership of navigable water rights

is “deeply rooted in history” and implicates the “equal

footing doctrine.” Utah Div. of State Lands v. United

States, 482 U.S. 193, 195 (1987). Under English

common law, the sovereign held “title” to all land

under navigable waters. Id. This title to navigable

waters “was considered an essential attribute of

sovereignty.” Id. The original thirteen colonies

claimed this sovereign title when they declared

independence from Britain, and any state that

subsequently joins the Union—including western

states—enters with this same sovereign title over its

navigable waters. Id. at 196; see Ch. 656, § 1, 26 Stat.

215, 215 (1890) (admitting Idaho “into the union on an

equal footing with the original states in all respects

whatever”). Because of its importance to the

traditional sovereign power of states, this Court does

not “lightly infer a congressional intent to defeat a

State’s title to land under navigable waters.” Utah

Div. of State Lands, 482 U.S. at 197.

Accordingly, Congress must speak clearly when its

actions “would result in a significant impingement of

the States’ traditional and primary power over land

and water use.” SWANCC, 531 U.S. at 174 (emphasis

added). And interpreting “public lands” to include

navigable waters in which the United States owns an

implied federally-reserved water right would result in

11

a significant impingement of the States’ traditional

authority over navigable waters within their borders.

Despite this, the Ninth Circuit’s opinion below

completely sidestepped the clear-statement doctrine.

The rationale given was that the doctrine is so longstanding that it “does not constitute ‘intervening’

authority” for purposes of disregarding the Ninth

Circuit’s prior interpretation of “public lands” in Title

VIII. Pet.App.39a. This created an odd Catch-22:

intervening precedent like Sturgeon was disregarded

in favor of old Ninth Circuit precedent, while

longstanding Supreme Court precedent was held not

to apply at all. In that sense, the opinion below was

consistent about one thing: this Court’s precedent, be

it old or new, must fall to the Ninth Circuit’s belief

that its pre-Sturgeon opinions must be right.

That artful dodge let the court off the hook from

identifying clear text in ANILCA supporting the

United States’s view of “public lands” in Article VIII.

The court never claimed such clarity exists. The

difficulty the court faced in distinguishing Sturgeon is

itself proof there is no such clear language in

ANILCA. If anything, the clear and consistent

interpretation of “public lands” in ANILCA is directly

contrary to the Ninth Circuit’s interpretation.

***

The Ninth Circuit’s interpretation of Title VIII of

ANILCA portends a significant shift in power from

the States to the federal government in the context of

reserved-water rights. But nobody, not even the

decision below, contends that Congress clearly

authorized that shift.

12

III.

Even if the United States Could Hold Title

to an Implied Water Right, the Ninth

Circuit’s Decision Was Still Wrong.

The arguments above should have resolved this

case in favor of Alaska: the Ninth Circuit’s holding

contradicts Sturgeon, § 3102, and the clear-statement

doctrine. But even if the United States were somehow

able to hold title in an implied federally-reserved

water right for purposes of Title VIII of ANILCA, the

decision below is still wrong because such a right must

be limited only to the minimal amount of water

necessary for the United States’s interest.

This Court held as much in Sturgeon, explaining

that even if the United States could hold title, it would

“merely enabl[e] the Government to take or maintain

the specific amount of water—and no more—required

to fulfill the purpose of [its land] reservation.” 587

U.S. at 44 (cleaned up). That tracked longstanding

precedent. “Each time this Court has applied the

implied-reservation-of-water doctrine it has carefully

examined both the asserted water right and the

specific purposes for which the land was reserved, and

concluded that without the water the purposes of the

reservation would be entirely defeated.” New Mexico,

438 U.S. at 700 (cleaned up).

“This careful examination is required both because

the reservation is implied, rather than expressed, and

because of the history of congressional intent in the

field of federal-state jurisdiction with respect to

allocation of water.” Id. at 701–02 (emphasis added).

Accordingly, the court can recognize only a

reservation of a “minimal need” of water. Cappaert v.

United States, 426 U.S. 128, 141 (1976).

13

Because of this need for careful examination, it is

vital that the proper channels determine the extent of

federal reserved water rights. Judicial adjudication

must determine the existence and scope of federal

reserved water rights, not back-door federal

regulations. For example, Idaho has engaged in

decades of litigation with the United States over

water rights, with hard-fought negotiation and careful

judicial determination of water rights in adjudications

like the Snake River Basin Adjudication. The Snake

River Basin Adjudication was a “27-year effort” that

culminated in a Unified Decree, in which “the court

decreed more than 158,600 water rights.” United

States v. Idaho, 746 F. Supp. 3d 881, 894–95 (D. Idaho

2024). The careful balance that these negotiations and

water right decrees struck would be upended if a

federal reserved water right transforms from a mere

right to use a specific quantity of water into the

authority to control and regulate a state’s navigable

waters.

It is therefore essential that the existence and

scope of federal reserved water rights are determined

by careful judicial inquiry in the context of an actual

adjudication. But in its decision below, the Ninth

Circuit failed to undertake this inquiry altogether.

***

The decision below pulled out all the stops to

resurrect and save the Ninth Circuit’s pre-Sturgeon

caselaw on the meaning of “public lands.” None of the

rationales provided for doing so are persuasive, and

they open the door to massive shifts in power from the

states to the federal government, especially across the

West, where federal land is abundant but water is

scarce. The Court should grant review and reverse.

14

CONCLUSION

For the foregoing reasons, amici urge the Court to

grant the petition.

Respectfully submitted,

R. TRENT MCCOTTER

WALKER FORTENBERRY*

BOYDEN GRAY PLLC

800 Connecticut Ave NW

Suite 900

Washington, DC 20006

(202) 706-5488

tmccotter@boydengray.com

*Admitted only in

Alabama; practice

supervised by D.C. Bar

Members

October 17, 2025

RAÚL R. LABRADOR

Attorney General

ALAN HURST

Solicitor General

Counsel of Record

MICHAEL A. ZARIAN

Deputy Solicitor General

SCOTT L. CAMPBELL

ROBERT M. FOLLETT

W. DALLAS BURKHALTER

MARSHALL W. TORYANSKI

Deputy Attorneys General

OFFICE OF THE IDAHO

ATTORNEY GENERAL

700 W. Jefferson St.

Ste. 210

Boise, ID 83720

alan.hurst@ag.idaho.gov

(208) 334-2400

15

ADDITIONAL SIGNATORIES

STEVE MARSHALL

Attorney General

AUSTIN KNUDSEN

Attorney General

TIM GRIFFIN

Attorney General

MICHAEL T. HILGERS

Attorney General

JAMES UTHMEIER

Attorney General

DREW H. WRIGLEY

Attorney General

THEODORE E. ROKITA

Attorney General

DAVE YOST

Attorney General

BRENNA BIRD

Attorney General

GENTNER DRUMMOND

Attorney General

LIZ MURRILL

Attorney General

ALAN WILSON

Attorney General

LYNN FITCH

Attorney General

MARTY JACKLEY

Attorney General

CATHERINE L. HANAWAY

Attorney General

JONATHAN SKRMETTI

Attorney General

State of Alabama

State of Arkansas

State of Florida

State of Indiana

State of Iowa

State of Louisiana

State of Mississippi

State of Missouri

State of Montana

State of Nebraska

State of North Dakota

State of Ohio

State of Oklahoma

State of South Carolina

State of South Dakota

State of Tennessee

16

KEN PAXTON

Attorney General

State of Texas

DEREK BROWN

Attorney General

State of Utah

JOHN B. MCCUSKEY

Attorney General

State of West Virginia

STEVE MONTENEGRO

Speaker of the House of

Representatives

State of Arizona

By counsel:

Linley Wilson

Majority General

Counsel

Arizona House of

Representatives

1700 W. Washington St.

Phoenix, Arizona 85007

lwilson@azleg.gov

(602) 926-5418

WARREN PETERSON

President of the Senate

State of Arizona

By counsel:

Rusty D. Crandell

Majority General

Counsel

Arizona State Senate

1700 W. Washington St.

Phoenix, Arizona 85007

rcrandell@azleg.gov

(602) 926-3137