Amigos Bravos v. United States Bureau of Land Management

BLM moved to dismiss on standing grounds. The district court granted the motion, holding that plaintiffs failed to demonstrate that their members suffered any injury in fact given that they produced no scientific evidence concerning statements in members’ declarations that climate change would lead to less water, decreased biodiversity, siltier rivers, and more forest fires. Thus, these statements were excluded as inadmissible hearsay. The court further held that even it were to accept such statements, none of the alleged effects of climate change created a risk of imminent environmental harm. In addition, the court held that none of the plaintiffs demonstrated that their members used the lands that would be subject to the leases. Finally, the court held that plaintiffs also failed to demonstrate causation concerning these alleged effects and the granting of the leases.