This case strove to protect the traditional rainbow trout subsistence fisheries in the navigable waters in the Togiak National Wildlife Refuge.

Visits to the Kanektok River was booming, and it threatened the Village's subsistence lifestyle. The villagers were afraid that visits to the river would pollute the water that they depend on and hurt fish stocks. The number of guides was frozen at 11. This case just eliminated motor boat use on the Kanektok; other rivers in the Togiak Refuge are still open to boaters.