Wilkie v. Robbins
United States Supreme Court case
Wilkie v. Robbins, 551 U.S. 537 (2007), was a United States Supreme Court case that concerned the scope of qualified immunity for government officials working in the Bureau of Land Management (BLM). Specifically, the Supreme Court held that BLM employees could not be liable for an alleged retaliation claim against Robbins, a farm owner, because other avenues for relief were available. Though these workers may have been tough in negotiations with Robbins over access over his land, none of that rose to the level of a constitutional violation.
Background
In 1994, Frank Robbins purchased a Wyoming dude ranch which functioned as a commercial guest resort. The original owner of the property had signed an agreement with the BLM granting an easement along a road which crossed the ranch. The Bureau failed to record the easement, and it ceased to exist when the property was transferred to Robbins. Robbins continued to graze cattle in the area, leading to a BLM employee demanding a new easement to replace the old one. At trial, Robbins claimed that employees of the BLM engaged in a "campaign of harassment and intimidation aimed at forcing him to re-grant the lost easement."
In 1998, after a series of further conflicts with BLM officials, Robbins filed a lawsuit. He claimed that the BLM actions violated the RICO statute, a law which bars racketeering.
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