Cottonwood Environmental Law Center v. Olson

ELR Citation: 54 ELR 20149
No(s). 23-4229 (9th Cir. Oct 25, 2024)

In an unpublished opinion, the Ninth Circuit affirmed dismissal of a challenge to the Forest Service's approval of sheep grazing allotments in Beaverhead Deerlodge National Forest. An environmental group argued the Service overlooked new information on grizzly bear mortality and conflicts with sheep dogs. The appellate court found the district court correctly dismissed the group's request to compel the Service to complete its planned environmental analyses for lack of subject matter jurisdiction because the Service already fulfilled its duty to conduct analyses under NEPA; and correctly found the Service did not violate NEPA because it reasonably concluded it did not have to prepare a supplemental analysis after a dead bighorn ewe was found in one of the allotments. It affirmed dismissal.

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