Tongass Alaska Girl Scout Council v. Cape Fox Corp.

ERA VII — Corporate Maturation & Expansion
Court Case
1994

It is undisputed that the Girl Scouts did not occupy the lands in question at the time Cape Fox received its patent in 1979. Cape Fox argues that this renders the Girl Scouts ineligible for a reconveyance. The Girl Scouts filed the current complaint in May 1993.

What Happened

This court reviews the district court’s grant of summary judgment de novo. Jesinger v. Nevada Fed. Credit Union, 24 F.3d 1127, 1130 (9th Cir. 1994).The Girl Scouts argue that they are entitled to a reconveyance under 43 U.S.C. § 1613(c)(2). Section 1613(c) provides:Patent requirements; order of conveyance; vesting date; advisory and appellate functions of Regional Corporations on sales, leases or other transactions prior to final commitment.

Why It Matters Today

Adds precedent that influences how ANCSA corporations, regulators, and shareholders interpret governance rights and remedies.

Related Patterns

Pattern 7: Cultural Expectations vs. Corporate Law

Related Governance Themes

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Sources

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