Montana Environmental Information Center v. United States Bureau of Land Management

The Ninth Circuit Court of Appeals reversed a district court’s dismissal on standing grounds of environmental groups’ lawsuit challenging federal approvals for oil and gas leasing on federal lands in Montana. The Ninth Circuit’s unpublished decision said that the Montana district court had erred when it failed to consider surface harms caused by the development of the leases and instead focused only on climate change-related effects, which the district court said did not create a concrete and redressable injury. The Ninth Circuit remanded to the district court with instructions to determine which lease sales would harm the areas of land enjoyed by the environmental groups’ members. The Ninth Circuit directed that this determination “should include consideration of any actual injury stemming from surface harms fairly traceable to the challenged action.”