ELR Citation: 56 ELR 20001
No(s). CV-18-69-GF-BMM (D. Mont. Dec 17, 2025) (Morris, J.)

A district court denied DOI's motion to voluntarily remand oil and gas leasing decisions in a lawsuit brought by conservation groups over BLM's 2018 instruction memorandum on greater sage-grouse conservation and six subsequent Montana and Wyoming lease sales. DOI argued the "One Big Beautiful Bill Act" (OBBBA) changed how BLM must consider expressions of interest when conducting its leasing process, that BLM's revisions to the greater sage-grouse resource management plan might remove or change the prioritization objective central to the groups' FLPMA claims, and that new NEPA regulations changed the groups' NEPA claims. The court found DOI failed to demonstrate congressional intent for BLM to apply the OBBBA’s provisions to past lease sale determinations, and that the Department could not rely on new or potential laws that would apply to future leasing decisions to demonstrate intent to reconsider or review their previous decision. It denied the motion to remand.