16 U.S.C. § 4
Section 4 · Rights-of-way through public lands
Amended 1 time on record
Applied in 457 court decisions — leading case Earth Island Institute v. United States Forest Service (2006)
Most recently applied in Wudi Industrial (Shanghai) Co., Ltd. v. Wai Wong (July 2025)
Cases citing this section usually also cite 15 U.S.C. § 4 · 4 U.S.C. § 4 · 9 U.S.C. § 4
How often courts cite this section
Court decisions citing this, by year.Markers show enactment, consequential amendments, and circuit splits over this section — watch for a citation surge after a change or a disagreement. The dip in the last several years is a data-coverage gap, not a real trend — our corpus holds fewer opinions from the most recent years, so recent citations are undercounted.
The provisions of sections 1, 2, and 3 of this title shall not affect or modify the provisions of section 79 of this title.
Editorial notes U.S. Code · Office of the Law Revision Counsel
References in Text
Section 79 of this title, referred to in text, was in the original a reference to act Feb. 15, 1901, ch. 372, 31 Stat. 790. For further details, see Codification note set out under section 79 of this title.
Cross References
Uniform application of this section to all areas of national park system when not in conflict with specific provisions applicable to an area, see section 1c of this title.