the validity of their claims in court.” Memorandum from the Secretary of the Interior to the Assistant Secretaries, Interim Departmental Policy on Revised Statute 2477 Grant of Right of Way for Public Highways; Revocation of December 7, 1988 Policy 2 (Jan. 22, 1997). 12 . Examples of administrative determinations include Southern Utah Wilderness Alliance, 111 IBLA 207, 214 (1989) (''[W]hile the courts may be the final arbiters whether a given R.S. 2477 right-of-way has legal existence, initial action defining and determining such a right-of-way is properly taken by BLM" when the issue is one “of 'administrative concern’ and requires resolution by BLM in the administration of Departmental regulations respecting planning and permitting.”); Leo Titus, Sr., 89 IBLA 323, 337-38 (1985) (<HOLDING>); Nick DiRe, 55 IBLA 151, 154 (1981) ("[W]hile
recognizing that there are no formal procedures for determining the validity of rs 2477 claims recognizing the rule and the exception but holding facts did not support claim to exception recognizing general rule recognizing the public interest exception 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