Judge Holte, relying on the work of Professor Gregory Ablavsky, contends that because the Property Clause was drafted while the Northwest Ordinance was passed and being worked out, it provided that “Congress would have a limited governing role over federal land after statehood.” But Ablavasky’s work is much more nuanced, emphasizing that while one reading of the Property Clause could be understood as limiting federal ownership of land, “the Convention punted on the question of state and federal ownership, explicitly entrenching the status quo.” Gregory Ablavsky, The Rise of Federal Title, 106 Cal. L. Rev. 631, 644 (2018) (citing U.S. Const. Art. IV, § 3, cl. 2 (“[N]othing in this Constitution shall be so construed as to Prejudice any Claims of the United States, or of any particular State.”)).