Friends of the Earth v. Haaland

In an unpublished judgment, the D.C. Circuit Court of Appeals held that a case challenging Lease Sale 257 for the development of oil and gas resources in the Gulf of Mexico was moot because the Inflation Reduction Act (IRA) included instructions for the Secretary of the Interior to issue leases to the high bidders. A district court had vacated the Bureau of Ocean Energy Management’s record of decision in January 2022 for failure to comply with NEPA. Because the legislative act mooted the case, the D.C. Circuit vacated the January 2022 district court order and remanded with instructions to dismiss. The D.C. Circuit rejected environmental groups’ arguments that a live controversy remained. The court concluded that the IRA did not condition issuance of the leases on the outcome of the appeal of the January 2022 order; that the IRA made clear that issuance of the leases was nondiscretionary and no longer subject to NEPA; and that the IRA did not intrude on the judiciary’s independence.

The D.C. Circuit denied American Petroleum Institute's emergency motion to expedite the appeal because all parties agreed that the U.S. Department of the Interior could still award leases pursuant to the lease sale if the D.C. Circuit reversed the district court’s vacatur of the lease sale. The court also referred to the merits panel a motion to dismiss the appeal for lack of jurisdiction by Friends of the Earth and the other appellees.