Carter Reservoir Mustangs, Inc. v. United States Department of Interior

ELR Citation: 56 ELR 20091
No(s). 2:25-cv-3252 WBS DMC (E.D. Cal. Jul 8, 2026) (Shubb, J.)

A district court granted nonprofit groups' and individuals' motion to preliminarily enjoin the scheduled removal of "excess" wild horses in northeastern California. Plaintiffs primarily challenged BLM's 2025 authorization of a plan to gather and remove wild horses in three herd management areas (HMAs), arguing the gathers violated the Wild Free-Roaming Horses and Burros Act (WHA), FLPMA, NEPA, and the APA. The court found BLM acted arbitrarily and capriciously by failing to consider the actual growth rates of the horse populations at issue, and thus that plaintiffs were likely to succeed on the merits of their WHA claim. It further found plaintiffs would likely suffer irreparable harm absent injunctive relief and that the balance of equities and public interest favored granting such relief. It granted plaintiffs' motion and enjoined BLM from implementing the plan to remove horses in the three HMAs.

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