Defenders of Wildlife v. Martin case brief

Defenders of Wildlife v. Martin case brief
454 F.Supp.2d 1085

CASE SYNOPSIS: Plaintiffs, environmental groups and others, brought an action in which they challenged biological opinions issued by defendant United States (U.S.) Fish and Wildlife Service and actions by defendant U.S. Forest Service (USFS), alleging they violated the Endangered Species Act of 1973 (ESA), 16 U.S.C.S. § 1531 et seq. Plaintiffs moved for an injunction and moved for partial summary judgment. Defendants cross-moved for partial summary judgment.

FACTS: Plaintiffs sought to prohibit defendants' authorization of snowmobiling and trail grooming within the caribou recovery area inside the Idaho Panhandle National Forest (IPNF) because it jeopardized and took the endangered woodland caribou. Plaintiffs asked the court to issue an injunction to prohibit the USFS from authorizing snowmobiling or snowmobile trail grooming in the "caribou recovery area" until it had adequately completed consultation over the effects of these activities on woodland caribou.

DISCUSSION

• The court found that because there was an agency action it had the authority to issue an injunction after reinitiation of consultation to prohibit activities that potentially violated the ESA during the consultation process. 
• Based on the undisputed evidence that the caribou had been harassed, the USFS's failure to prepare and implement a comprehensive recreation management strategy jeopardized the continued existence of the caribou. 
• Defendants' reinitiation of consultation had rendered the claims set forth in plaintiffs' motion for partial summary judgment moot.

CONCLUSION: Plaintiffs' motion for injunctive relief was granted but their motion for partial summary judgment was denied. Defendants' cross-motion for partial summary judgment was granted.