ELR Citation: 56 ELR 20081
No(s). CV-18-69-GF-BMM (D. Mont. Jun 12, 2026) (Morris, J.)

A district court granted in part and denied in part conservation groups' motion for summary judgment in an ongoing lawsuit over oil and gas lease sales on public lands in Wyoming, Montana, and the Dakotas that encompass greater sage-grouse habitat. The groups challenged BLM's issuance of an instruction memorandum (IM) on sage-grouse conservation and the subsequent oil and gas leasing decisions. In its initial ruling, the court vacated the 2018 IM and three lease sales in Wyoming and Montana because they violated FLPMA by failing to properly implement BLM's 2015 resource management plans' (RMPs') priority requirements established to conserve sage-grouse habitat. In a subsequent ruling, the court determined the five remaining lease sales being challenged also violated FLPMA for failing to properly implement the 2015 priority requirement. Here, the court considered six Montana/Dakotas and Wyoming lease sales, finding the 2019 Wyoming and the Montana/Dakotas lease sales also failed to incorporate the 2015 requirement, in violation of FLPMA; but it declined to reach the claims challenging the 2020 Wyoming lease sales because BLM has yet to issue them. The court granted summary judgment for the groups as to their claims that the 2018 IM and 2019 Wyoming and Montana/Dakotas lease sales violated FLPMA, and granted summary judgment for BLM as to the 2020 Wyoming lease sales. It remanded with vacatur the lease sales that violated FLPMA, excluding nine leases already producing, and dismissed the 2020 Wyoming lease sales for lack of final agency action.