A district court denied an animal rights group's motion for summary judgment in a challenge to permits and safe harbor agreements issued by FWS for an experiment on nonfederal land to gain data on the relationship between barred owl removal and northern spotted owl recovery.

President Donald Trump’s environmental policies appear detrimental to the environmental justice movement, but little work has been done to test their true impact on EJ. This Article offers a method for evaluating progress (or lack thereof) across the last three presidential administrations, proposing three metrics for progress: access to legal recourse, consideration of climate change as an EJ issue, and signaling actions.