Former Interior Secretary David Bernhardt did this during the 2019 government shutdown and the Government Accountability Office found his actions were illegal. Barrasso requested Haaland use the exact same funding mechanism that Bernhardt did, even though the GAO found that using FLREA funds to keep parks open during a shutdown was illegal.
Please see a document
HERE that details Bernhardt's actions in 2019, the GAO response, and Barrasso's request from yesterday.
Let me know if you have any questions!
Best,
Chad
-- Chad Ellwood
Beehive Research