The D.C. Circuit denied environmental groups' petition to review FERC's approval of 1,000 feet of natural gas pipeline along the Texas-Mexico border. The groups argued FERC needed to exercise jurisdiction over a much longer stretch that begins at the 1,000-foot border pipeline and runs for 157 miles into rural Texas, and that even if it properly declined jurisdiction under §7 of the Natural Gas Act, it should still have considered that pipeline's environmental impacts. They also argued FERC violated NEPA by failing to consider alternatives to the border-crossing pipeline and that the Commission's approval of that pipeline was arbitrary and capricious. The court found FERC reasonably declined to exercise §7 jurisdiction over the longer stretch of pipeline because it was located entirely within Texas, would carry only intrastate gas upon commencing service, and would have access to nearly double its own capacity of intrastate gas via eight upstream sources. The court further found FERC's alternatives analysis did not violate NEPA because it wasn't required to consider alternatives outside its jurisdiction, and that the groups failed to show that approving the border-crossing pipeline was inconsistent with the public interest. It denied the petition.

The D.C. Circuit affirmed dismissal of a challenge to an FWS rule downlisting the American burying beetle from endangered to threatened and to its ESA §4(d) rule establishing protections for conservation of the beetle based on the downlisting. An environmental group argued the downlisting rule was inconsistent with the ESA and that the decision to downlist was arbitrary and capricious because it provided less stringent protections in the Southern Plains than in other regions. A district court concluded FWS reasonably determined that the predicted serious threats to the beetle's continued existence in the 2040-2069 time period qualified as within the "foreseeable future" for purposes of threatened species status, but did not make the beetle "in danger of extinction" now; and that the downlisting rule and the Service's tailoring of the §4(d) protections were supported by the record and adequately explained. The appellate court found FWS' conclusion that the beetle was not endangered when it issued the downlisting rule in 2020 fell within the bounds of reasonable judgment and was consistent with the record evidence, and that the group failed to establish standing as to its §4(d) challenge. It affirmed dismissal.

The Eleventh Circuit affirmed dismissal of a CWA citizen suit brought against a hotel owner for filling a nearby wetland. Environmental groups argued the hotel violated the CWA by failing to comply with Nationwide Permit 39 and failing to comply with Georgia's water quality certification. The hotel moved to dismiss on the ground that the wetland did not satisfy the test for "waters of the United States" under Sackett v. Environmental Protection Agency, 143 S. Ct. 1322, 53 ELR 20083 (2023). A district court granted the motion, finding the groups failed to allege facts that would establish that the wetland was a water of the United States under Sackett. The appellate court found the groups failed to allege sufficient facts to support a conclusion that the wetland had a continuous surface connection to a water of the United States, and affirmed dismissal.

A district court granted in part and denied in part environmental groups' motion for a temporary restraining order (TRO) in a challenge to the federal government's construction and operation of a mass immigrant detention and deportation facility in the Florida Everglades. The groups argued construction and operation of the project without any environmental review violated NEPA, and sought to enjoin the state of Florida and the federal government from developing or using the site as a detention facility until the government complies. A few weeks after the suit was filed, the facility completed its first phase of construction and ongoing operations, and the groups sought a TRO to halt further construction, pause transportation of additional detainees to the site, and cease operations related to detaining or preparing to detain anyone not already there. The court found that the government's control over the facility's operations, evidence that construction was at the request of the Department of Homeland Security, and regular inspections by Immigration and Customs Enforcement officials, combined with the undisputed lack of any prior environmental assessment, created a sufficient likelihood of success on the groups' claim. It further found the balance of equities and public interest favored granting a TRO because the harm to the government from briefly suspending expansion of the facility was minimal and was not preventing continued operations there nor additional detainees from being brought there if current capacity allowed; but that if the facility were expanded, it would be difficult to change course. The court entered a TRO prohibiting Florida and the federal government from installing new industrial-style lighting; doing any paving, filling, excavating, or fencing; or doing any other expansion, including placing or erecting additional buildings, tents, dormitories, or other residential or administrative buildings on the site, until the court enters an order as to the groups' motion for preliminary injunction.

A district court ruled for environmental groups in a challenge to FWS' 2024 finding that listing a distinct population segment (DPS) of gray wolves in the western United States under the ESA was not warranted. The groups argued FWS failed to consider a "significant portion" of the gray wolf's range by ignoring historical range and discounting both Colorado and the West Coast, failed to consider the best available science on gray wolf populations and the impacts of human-caused mortality, and failed to evaluate the threat to gray wolves from inadequate existing regulatory mechanisms. The court found FWS' interpretation of "range" to categorically include only a species' current or occupied range was contrary to the Act, that the Service failed to adequately explain why it relied extensively on Colorado's future contributions to the western DPS while also discounting its significance on purely quantitative grounds, and that its determination that the gray wolf in the West Coast area was not likely in danger of extinction in the foreseeable future was contrary to the record evidence. The court further found FWS failed to use the best available science by relying on population estimates for Idaho and Montana without addressing criticisms raised, and that the Service failed to consider the possibility that states could not hold their commitment to a minimum wolf population. It vacated and remanded FWS' finding.

A district court denied business groups' motion to preliminarily enjoin two California laws that require large businesses to disclose their greenhouse gas emissions (S.B. 253) and climate-related financial risk (S.B. 261). The groups challenged the laws on First Amendment grounds. The court found the groups did not show a likelihood of success as to their challenge to S.B. 253, given California's duel interests in providing reliable information on which to make investment decisions and in reducing emissions; nor did they show a likelihood that the state's interest in providing reliable information to investors failed intermediate scrutiny in a substantial majority of S.B. 261's applications. It further found the balance of equities did not favor the groups because enjoining the laws would delay the state from advancing the public interests for which it adopted them. The court denied the motion.

A district court denied environmental groups' motion for summary judgment in a challenge to a 2019 EPA rule that exempted air emissions from animal waste from an EPCRA reporting requirement. The groups argued the rule contravened EPCRA by concluding animal waste emissions were no longer reportable under §304(a)(2) following their 2018 exemption from CERCLA's notification requirements via the Fair Agricultural Reporting Method (FARM) Act, that EPA failed to consider the public's right to access information and changed course without explanation, and that EPA violated NEPA by failing to conduct an environmental impact analysis. The court found that CERCLA's exemption for air emissions from animal waste at farms—which targets the "nature" of such releases, or the "way in which" releases happen—meant that such releases "do not occur" in a manner that requires CERCLA §103(a) reporting for purposes of EPCRA §304(a)(2). It further found the rule was not arbitrary or capricious because it was consistent with the best reading of §304(a)(2) and provided a reasoned explanation for exempting the emissions. The court also found EPA was not obligated to consider environmental information because it was compelled by the FARM Act to issue the rule. The court denied the groups' motion for summary judgment and granted EPA's cross-motion.