Federal lands are lands in the United States owned by the federal government. Pursuant to the Property Clause of the United States Constitution (Article 4, section 3, clause 2), Congress has the power to retain, buy, sell, and regulate federal lands, such as by limiting cattle grazing on them. These powers have been recognized in a long line of United States Supreme Court decisions. The only mention in the United States Constitution of the specific types of land the federal government is authorized to own outside Washington D.C., in Article 1, Section 8, refers to "Places purchased by the Consent of the Legislature of the State in which the same shall be, for the erection of Forts, Magazines, Arsenals, Dock-yards, and other needful Buildings." The federal government owns about of land in the United States, about 28% of the total land area of . The majority of federal lands ( or 95 percent area in 2015) are administered by the Bureau of Land Management (BLM), United States Fish and Wildlife Service (FWS), National Park Service (NPS), or United States Forest Service (USFS). BLM, FWS, and NPS are part of the United States Department of the Interior, while the Forest Service is part of the United States Department of Agriculture. An additional of land (about 2% of all federal land) is owned by the United States Department of Defense (DOD). The majority of federal lands are located in Alaska and the Western states. The United States Supreme Court has upheld the broad powers of the federal government to deal with federal lands, for example having unanimously held in Kleppe v. New Mexico that "the complete power that Congress has over federal lands under this clause necessarily includes the power to regulate and protect wildlife living there, state law notwithstanding." Lands held by the United States in trust for Native American tribes are generally not considered public lands. There are some of land held in trust by the federal government for Indian tribes and almost of land held in trust by the federal government for individual Natives.