Southern Utah Wilderness Alliance v. Bureau of Land Management, 425 F.3d 735 (10th Cir.2005), the court of appeals examined the BLM’s authority to determine R.S. 2477 right-of-way claims, and did so at some length. In that ease, Kane County and Garfield County argued that the BLM’s administrative determinations of several of the Counties’ R.S. 2477 right-of-way claims were invalid because the agency had no formal procedure for making administrative R.S. 2477 determinations and could not exercise primary jurisdiction over such claims: In its 1993 Report to Congress on R.S. 2477, the Department of the Interior states: “No formal process for either asserting or recognizing R.S. 2477 rights-of-way currently is provided in law, regulations, or DOI policy.” DOI 1993 Report to Congress at 25 (<HOLDING>): That circumstance remains. In the absence of
recognizing an administrative necessity exception to the general rule that state courts are the proper forum for determining whether there is a public highway under rs 2477 and the respective rights of interested parties recognizing that there are no formal procedures for determining the validity of rs 2477 claims recognizing that  502b1 requires bankruptcy courts to consult state law in determining the validity of most claims recognizing the crawford interrogation was more formal but determining the interrogation of hammons wife was formal enough in considering that factor and determining the wifes statements were testimonial recognizing that the process of allowance or disallowance includes determining the legal validity of a claim against the debtor