WildEarth Guardians v. Haaland

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On April 15, 2021, federal defendants, defendant-intervenors, and environmental groups filed a stipulation for dismissal of appeals of a district court’s November 2020 decision finding that the U.S. Bureau of Land Management’s (BLM’s) supplemental environmental assessment (EA) for oil and gas leases in Wyoming did not comply with the National Environmental Policy Act because it failed to adequately consider climate change impacts. BLM prepared the supplemental EA in response to the court’s decision in March 2019 that identified shortcomings in BLM’s original climate change analysis for the leases. The federal defendants, the States of Wyoming and Utah, and several trade groups appealed the district court’s November 2020 decision.

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In three lawsuits brought by conservation groups to challenge oil and gas leases on federal land in Colorado, Montana, New Mexico, Utah, and Wyoming, the federal district court for the District of Columbia granted the conservation groups’ motions for voluntary dismissal with prejudice after the groups and the federal defendants reached agreements to settle the three cases. Under the agreements, the U.S. Bureau of Land Management (BLM) will conduct additional National Environmental Policy Act analysis, consistent with the court’s earlier decisions that found flaws in BLM’s analysis of the leases’ impacts on climate change. In its decision granting voluntary dismissal, the court found that the plaintiffs sought voluntary dismissal in good faith and that industry defendant-intervenors did not establish that voluntary dismissal would result in clear legal prejudice to them (or undue prejudice, if reviewed under the standard for voluntary remand, as the intervenors argued). Having granted voluntary dismissal, the court denied as moot federal defendants’ motions to dismiss for lack of subject matter jurisdiction, federal defendants’ motions to remand, and intervenors’ motions to dismiss on statute of limitations grounds.

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