In 2010 the Wisconsin State Journal reported a battle brewing in Perry, a small rural town in Dane County, in the southern part of the state. The conflict concerned the land around a historic church. At the heart of the matter was a more general question: who has the right to decide how land will be used? The answer may seem simple. In the United States, “the property owner is the primary land use decision maker,” wrote one scholar of land law in 2004. In practice, however, land use questions are often extremely complicated, whether they involve a small country church or a vast expanse of wil- derness. In disputes over land use, the property owner may not be the only decision maker, or the final one.