League of Conservation Voters v. Trump

The Ninth Circuit Court of Appeals vacated the judgment of an Alaska federal district court that held that President Trump exceeded presidential authority granted by the Outer Continental Shelf Lands Act when he issued an executive order revoking President Obama’s withdrawals of certain areas in the Arctic and Atlantic Oceans from oil and gas leasing. The Ninth Circuit agreed with the parties that President Biden’s revocation of President Trump’s executive order rendered the case moot. The Ninth Circuit directed the district court to dismiss the case without prejudice.

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The federal district court for the District of Alaska denied environmental organizations’ motion pursuant to Federal Rule of Civil Procedure 60(b)(6) to reinstate the district court’s 2019 judgment determining that President Trump lacked authority to revoke President Obama’s withdrawals of certain areas on the outer continental shelf (OCS) from future oil and gas leasing. After President Biden issued an executive order in 2021 rescinding President Trump’s revocation, the Ninth Circuit concluded that the case was moot and vacated the district court’s judgment. The environmental organizations filed their Rule 60(b)(6) motion after President Trump issued Executive Order 14148 on January 20, 2025 rescinding the Biden executive order as well as President Biden’s additional withdrawals of OCS areas from oil and gas leasing. The district court agreed with defendant-intervenors American Petroleum Institute and the State of Alaska that the Ninth Circuit’s mandate did not permit the court to reinstate its 2019 judgment. The district court concluded that because the effect of possible future action had been addressed before the Ninth Circuit in briefing on the mootness question, the Ninth Circuit had “held by necessary implication that an exception to mootness premised on a recurrence of the allegedly unlawful conduct did not apply.” The district court stated that the plaintiffs could seek relief by filing a new complaint in this action or by adding the issue of Executive Order 14148’s impact on the 2017 withdrawal revocation to a separate <a href="https://climatecasechart.com/case/northern-alaska-environmental-center-v-trump/">pending</a> lawsuit challenging the revocation of President Biden’s additional withdrawals.

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