Iron Bar Holdings, LLC v. Cape
2025 property law case in United States
Iron Bar Holdings, LLC v. Cape was an October 2025 legal case involving property law and public access to federal lands in Wyoming. At issue was whether corner crossing on foot without physically contacting private land and without causing damage to private property constituted an unlawful trespass. The case's outcome has potentially opened up over 3,000,000 acres (12,000 km2) of public land for public access in the United States.
Historical background
A checkerboard-like pattern of government land and private land was created in the American West during the construction of the Transcontinental Railroad in the 1800s. Recognizing the potential for these government parcels to be "unlawfully appropriated" and "to prevent the absorption and ownership of vast tracts of our public domain", and as a reaction to range wars, the United States Congress passed the Unlawful Inclosures Act (UIA) of 1885 (43 U.S.C. § 1061-1066), making it unlawful to exclude the public from public lands by means of inclosure.
Case background
In 2020, three hunters, Bradley Cape, Zachary Smith, and Phillip Yeomans, traveled to Wyoming to hunt on checkerboarded BLM land on Elk Mountain, southwest of the town of Elk Mountain. During their hunt, they crossed between BLM parcels by corner crossing, passing through the airspace over private land held by Iron Bar Holdings, LLC (IBH), owned by Fred Eshelman, founder of PPD, Inc.At one of these corners, IBH had run a locked chain between two private property signposts fixed on parcels owned by IBH, requiring the hunters to grab the signposts and swing around them to get to BLM land.
IBH's property manager, Steven Grende, discovered the hunters on public land that he believed was only accessible by trespassing, and demanded that the hunters leave the area. In a later deposition, Eshelman stated IBH had a company policy for employees to confront individuals found either on public land near IBH property or on IBH property.
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