Western Watersheds Project v. Grimm, No. 18-35075 (9th Cir. 2019)
Annotate this CaseThe Ninth Circuit reversed the district court's dismissal of an action brought by conservationist groups to enjoin the federal government's participation in the killing of gray wolves in Idaho pending additional analysis under the National Environmental Policy Act of 1969 (NEPA). The panel held that the conservationist groups had Article III standing because declarations from members described how USDA Wildlife Services's wolf-killing activities threatened their aesthetic and recreational interests. Therefore, the members established that the interests fell within the scope of NEPA's protections and they established an injury-in-fact. The panel noted that causation was established under the relaxed standard for procedural injuries. Finally, the panel held that the district court erred in finding that plaintiffs' injuries were not redressable and in relying on an unpublished opinion that lacked precedential value.
Court Description: Environmental Law / Article III Standing The panel reversed the district court’s dismissal for lack of Article III standing of an action brought by plaintiff conservationist groups to enjoin the federal government’s participation in the killing of gray wolves in Idaho pending additional analysis under the National Environmental Policy Act. The panel analyzed the requirements of Article III standing that plaintiffs had the burden of establishing. First, the panel held that eight declarations from plaintiffs’ members describing how USDA Wildlife Services’ wolf-killing activities threatened their aesthetic and recreational interests in tracking and observing wolves in the wild fell under the scope of NEPA’s protections, and established injury-in-fact.
Some case metadata and case summaries were written with the help of AI, which can produce inaccuracies. You should read the full case before relying on it for legal research purposes.
This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply.