Center for Biological Diversity v. Little

The federal district court for the District of Idaho enjoined Idaho from authorizing wolf trapping and snaring in grizzly bear habitat “except during the time period when it is reasonably certain that almost all grizzly bears will be in dens: December 1 to February 28.” The court found that conservation groups met their burden of establishing that Idaho’s recreational trapping laws and rules violated the Endangered Species Act. The court found, however, that although the groups established that future take of grizzly bears in lawfully set wolf traps and snares was reasonably certain, the groups did not identify a remedy tailored to Idaho’s circumstances. The court described the groups’ evidence that effects of climate change were causing grizzly bears to leave their dens sooner or enter them later as “mere generalities” and found that the plaintiffs did not establish the extent to which grizzly bear populations during denning season overlap with locations of permitted wolf trapping. The court therefore tailored the injunction to bar Idaho’s authorization of wolf trapping only outside “established denning periods” for grizzly bears.