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Central Oregon Wild Horse Coalition v. Vilsack

In an unpublished opinion, the Ninth Circuit affirmed summary judgment for the Forest Service in a challenge to its decision to approve a herd management plan for wild horses in Ochoco National Forest. A group of conservationists argued the Service violated the Wild Free-Roaming Horses and Burros Ac...

Small Populations in Jeopardy: A Delta Smelt Case Study

This Comment illustrates, through a case study of the Delta smelt BiOp, the difficulties in making ESA jeopardy determinations for species on the brink of extinction. We conclude that the myriad challenges inherent in conservation of some small and declining populations make reasoned §7 analysis difficult, bordering on impossible.