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Western Watersheds Project v. Grimm

ELR Citation: 49 ELR 20071
Nos. 18-35075, (9th Cir., 04/23/2019)

The Ninth Circuit reversed a dismissal of a lawsuit brought by conservation groups to enjoin USDA from killing gray wolves in Idaho pending additional NEPA analysis. The groups argued before the district court that the agency violated NEPA by failing to prepare an EIS on its wolf management activities in Idaho. The district court dismissed the action for lack of standing, holding that the groups had not shown their injuries were redressable because Idaho could engage in the same lethal operations without the help of USDA. The appellate court found the district court relied on the wrong precedent and failed to properly apply the relaxed standard for redressability in procedural injury cases. The proper inquiry was whether the groups had shown that halting the agency's wolf-killing activities pending additional NEPA analysis could protect their aesthetic and recreational interests in gray wolves in Idaho. The appellate court held the groups had showed as much, and therefore remanded for further proceedings.