"In its capacity as a custodian and manager of public lands, a local government commonly makes decisions that have the effect of restricting public access and the use of that land," the decision reads. "For example, a city parks bureau may decide to close trails within a public park to dog-walkers, in order to avoid conflict with other users, to prevent harm to wildlife, or for many other reasons that have little or nothing to do with land use planning or regulation, and which may not be governed by any standards at all.

