Living Rivers v. Hoffman

ELR Citation: 51 ELR 20118
No(s). 4:19-cv-00057-D (D. Utah Jun 21, 2021) (Nuffer, J.)

A district court dismissed a lawsuit concerning BLM's suspension of oil and gas leases sold in Utah in 2018. Environmental groups argued BLM violated NEPA by failing to prepare an EIS prior to suspending the leases. BLM moved to dismiss, arguing the groups lacked standing because the suspensions were not major federal actions and thus did not require NEPA compliance. The court found the suspensions were not major federal actions because they did not change the land, but rather prohibited any changes to the leased land, and thus did not "significantly affect the quality of the human environment." It therefore dismissed the suit.

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