Mayo v. Reynolds, No. 16-5282 (D.C. Cir. 2017)Annotate this Case
Plaintiffs filed suit challenging the Park Service's decision authorizing recreational hunting of elk in Wyoming's Grand Teton National Park. In regards to plaintiffs' claim under the National Environmental Policy Act (NEPA), 42 U.S.C. 4321, the DC Circuit affirmed the district court's grant of summary judgment to the Park Service. The court held that all the environmental effects seen during the years after the promulgation of the 2007 Plan and environmental impact study (EIS) had been anticipated and analyzed in the original environmental assessment, and thus the Park Service had no duty to prepare a supplemental or new EIS; plaintiffs failed to show that the Park Service acted arbitrarily or capriciously; and the Park Service has implemented the elk-reduction program in the manner envisioned by the 2007 Plan and analyzed in the 2007 EIS. Finally, the court vacated the district court's judgment in regard to the claim under the Endangered Species Act (ESA), 50 C.F.R. pt. 17, based on mootness grounds because the grizzly bear was no longer listed as a threatened species under the ESA.