Backcountry Against Dumps v. U.S. Bureau of Indian Affairs

The Ninth Circuit Court of Appeals affirmed the dismissal of a lawsuit against the Bureau of Indian Affairs challenging the authorization of a wind energy lease between the Campo Band of Diegueño Mission Indians and a renewable energy company. The Ninth Circuit noted that it was uncontested that the Band could not be joined in the lawsuit because of its sovereign immunity and agreed with the district court’s conclusion that the Band was a necessary party because the action’s disposition could affect the Band’s sovereign and economic interests, which would not be adequately represented by other parties to the lawsuit. The complaint’s allegations included that the federal defendants failed to disclose the project’s entire life cycle greenhouse gas emissions.