Kleppe v. New Mexico, , was a United States Supreme Court decision that unanimously held the Wild and Free-Roaming Horses and Burros Act of 1971, passed in 1971 by the United States Congress to protect these animals from "capture, branding, harassment, or death", to be a constitutional exercise of congressional power. In February 1974, the New Mexico Livestock Board rounded up and sold 19 unbranded burros from Bureau of Land Management (BLM) land. When the BLM demanded the animals' return, the state filed suit claiming that the Wild Free-Roaming Horses and Burros Act was unconstitutional; claiming the federal government did not have the power to control animals in federal lands unless they were items in interstate commerce or causing damage to the public lands.