The Ninth Circuit affirmed a district court's dismissal of an environmental group's request to compel DOI to reinstate the Refuges Rule, which prohibited Alaska's predator-control methods on national wildlife refuges. The group argued that Congress' joint resolution disapproving the rule violated the Take Care Clause, but the court found that the group failed to state a plausible claim because validly enacted legislation requiring an agency to take a specified action did not impinge on the Take Care Clause or violate separation-of-powers principles.

The plastic packaging industry faces mounting shareholder and public pressure to reduce the environmental impact of post-consumer plastic packaging. What are the opportunities and challenges of legislating a minimum recycled content requirement for the packaging industry?