ELR Citation: 54 ELR 20119
No(s). 23-CV-84-KHR, 23-CV-87-KHR, and 23-CV-117-KHR (D. Wyo. Aug 14, 2024) (Rankin, J.)

A district court affirmed BLM's resource management plan (RMP) amendment and record of decision (ROD) concerning wild horse management in southern Wyoming. Conservation and wild horse advocate groups argued BLM's decision to revert two herd management areas to "herd area" status, of which the appropriate management level for wild horse populations is typically zero, violated the Wild Free-Roaming Horses and Burros Act (WHA), FLPMA, and NEPA. The court found the groups' WHA arguments conflated the RMP amendment with a final horse removal decision and misconstrued BLM's obligations, and determined that the Bureau both complied with, and was justified in complying with, its obligations under FLPMA and NEPA. It upheld the RMP amendment and ROD.